Dakota Harvestore Systems, Inc. v. South Dakota Department of Revenue

331 N.W.2d 828 (1983)

DAKOTA HARVESTORE SYSTEMS, INC., Defendant and Appellant,

v.

SOUTH DAKOTA DEPARTMENT OF REVENUE, Plaintiff and Appellee.

No. 13875.

Supreme Court of South Dakota.

Considered on Briefs February 17, 1983.

Decided March 30, 1983.

Rehearing Denied May 4, 1983.

Frank P. Gibbs of Simons, Gibbs, Feyder & Myers, Sioux Falls, for defendant and appellant.

Gene R. Woodle, Asst. Atty. Gen., S.D. Dept. of Revenue, Pierre, for plaintiff and appellee.

HENDERSON, Justice.

PROCEDURAL HISTORY

In 1981, the South Dakota Department of Revenue (the Department) audited Dakota Harvestore Systems, Inc.…