OPINION1
GIBBONS, J.
In this appeal, we consider whether NAC 360.452 exceeds the scope of NRS Chapter 360. NRS 360.395 directs a person to pay a tax determination amount before seeking judicial review of a final Nevada Tax Commission decision. In lieu of immediately paying the determination amount, however, NRS 360.395 allows the entity to enter into an agreement to pay that amount at a later date. The type of agreement...
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