Mugglin, J.
By mid-1998, Ronald Cadillac-Oldsmobile, Inc. had two serious financial problems. First, it had filed sales and use tax returns with the state for the periods from December 1, 1995 through November 30, 1997 but had only paid minimal amounts of the taxes due. As a result, the Department of Taxation and Finance, Division of Taxation (hereinafter Division), between November 1, 1996 and November 16, 1998, issued five warrants exceeding, in toto, $1 million...
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