Smith v. State

CRAWLEY, Judge.

Clyde Randy Smith appeals from the circuit court’s dismissal of his appeal from a final jeopardy tax assessment.

On June 26, 1992, Smith was arrested for possession of marijuana. On February 9, 1993, the Department of Revenue entered a final jeopardy tax assessment of $3,695,937 against Smith, based on Smith’s failure to purchase and affix drug tax stamps for 527,-991 grams of marijuana, as required by Ala. Code 1975, § 40-17A-1 et seq.

In 1992, the legislature enacted the “Alabama Taxpayers’ Bill of Rights and Uniform Revenue Procedures Act.” That legislation, found at Ala.Code…