Grand Canyon Dories, Inc. v. Idaho State Tax Commission

JOHNSON, Justice.

This is a sales and use tax case. The dispositive issue on appeal is whether the district court had jurisdiction to review the redetermination of the deficiency by the State Tax Commission. We conclude that the district court did not have jurisdiction to do so and vacate the district court’s order determining the taxpayer’s liability.

I

THE BACKGROUND AND PRIOR PROCEEDINGS.

In 1981, the Commission issued two notices of deficiency determination to Grand Canyon Dories (GCD). The notices asserted that GCD owed sales and use tax, plus interest and penalties. The first notice…