The Louisiana Department of Revenue ("Department") conducted an audit of sales and use taxes owed by Hertz Equipment Rental Corporation ("HERC") between 1999-2003. The three-year prescriptive period for collection of the 1999 taxes under La. Const Art. VII, § 16 would have expired on December 31, 2002. Prior to this date, the Department sent a proposed agreement to HERC, requesting that HERC agree to a...
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