BLACKBURNE-RIGSBY, Associate Judge:
Appellant, Hospitality Temps Corporation ("HTC"), was issued a Notice of Tax Deficiency by the Office of Tax and Revenue ("OTR") pursuant to D.C.Code §§ 47-2002 and 47-2001 (2001) for failure to collect and pay sales and use tax. OTR denied appellant's motion appealing the tax assessment. Appellant next appealed to the Tax Division of the Superior Court pursuant to D.C.Code §§ 11-1201 and 47-2021(a) (2001). In...
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