State Department of Revenue v. Calhoun

The State Department of Revenue ("the Department") appeals from a summary judgment entered by the Circuit Court of Mobile County in favor of Clay J. Calhoun.

On October 17, 1988, the Department entered two preliminary assessments against Calhoun for oil and gas privilege taxes. Calhoun disputed the assessments, and attempts between Calhoun and the Department to informally resolve the disputes failed. In January 1989, Calhoun requested a formal hearing with the Department's Administrative Law Division. In a letter dated February 8, 1989, the administrative law judge notified Calhoun that his…