Sidhu v. Department of Revenue

I. INTRODUCTION

This matter comes before the court on the Motion for Summary Judgment of Defendant Department of Revenue (the department). At the September 20, 2006, case management conference, both the department and Plaintiffs (taxpayers) waived oral argument on the motion.

II. FACTS

On January 7, 2005, the department issued Notices of Assessment (NOAs) to MS Market, Inc., for unpaid tobacco tax, related penalties, and interest for tax years 2000 and 2001. Each NOA provides an explanation of the tax and a table showing the dates when tobacco was allegedly purchased by taxpayers from Lil' Brown…