SCHROEDER, Justice.
This is an appeal from the judgment of the Fourth District Court, which upheld a Notice of Deficiency issued by the Idaho State Tax Commission (Tax Commission) against Robert F. Ryder, dba Radio Paging Service (Radio Paging). The district court found that Ryder was liable for Idaho sales and use tax, plus penalties and interest, in the total amount of $48,789. Radio Paging appealed, and the Tax Commission cross-appealed the district court's allowance...
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