Hallmark Marketing Corp. v. Department of Revenue

HENRY C. BREITHAUPT, Judge.

This case was litigated and decided in the Magistrate Division on the merits, with proceedings and briefing completed prior to June 6, 2000, the date this court issued its decision in Dept, of Rev. v. IBM Corp., 15 OTR 162 (2000). Apparently as a result of the decision in IBM, in this division Plaintiff (taxpayer) raised the issue of the timeliness of notices of deficiency issued by the Department of Revenue (the department). By a pre-trial stipulation, the parties agreed that the issue of the timeliness of the department’s notices of deficiency should be resolved…