Dusty's, Inc. v. Auditing Division of the Utah State Tax Commission

Dusty’s, Inc., brought an original proceeding in this court seeking judicial review from a final Tax Commission order that imposed a sales tax on Dusty’s sale of warranties. The Commission moved for summary disposition on the ground that Dusty’s petition was untimely. This court granted the Commission’s motion by minute entry. Before us now is Dusty’s motion to reinstate the petition for judicial review. We deny that motion.

A brief sketch of the procedural facts is in order. On March 25, 1992, the chairman and three commissioners of the Commission signed a document entitled “Findings of…