THOMPSON, Judge.
On December 7, 1998, the State of Alabama Department of Revenue (the "Department") entered a "Notice of Final Assessment" against Taft Coal Sales and Associates, Inc. ("Taft"), for its failure to pay taxes pursuant to § 11-51-206, Ala. Code 1975. On January 6, 1999, Taft filed a notice of appeal, pursuant to § 40-2A-7(b)(5), Ala.Code 1975, to the Department's Administrative Law Division. On August 18, 1999, the administrative-law judge entered...
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