Wheeler v. Strickland

Gregory, Justice.

The State Revenue Department sought to impose sales tax on alleged illegal gambling activities of appellant Wheeler under the Georgia Retailers and Consumers Sales and Use Tax Act, Ga. Laws, 1951, p. 360 et seq., Code Ann. Chapter 92-34 (amended, Ga. Laws, 1978, p. 309 et seq., Code Ann. Chapter 91A-45). Wheeler, his attorney, and his accountant met with revenue officials on one occasion. Wheeler refused to communicate with the revenue officials thereafter. Subsequently, the Department of Revenue issued an official notice of assessment and demand for payment.

Wheeler appealed…