Dunn v. State ex rel. Oklahoma Tax Commission

MEMORANDUM OPINION

BAILEY, Judge:

Appellant Jack Dunn, d/b/a Dunn’s Fish Farm, (Dunn or Appellant) seeks review of an order of the Appellee Oklahoma Tax Commission sitting en banc (OTC or Appel-lee) denying Dunn’s Motion to Quash/Modify a subpoena duces tecum issued by OTC. Herein, Dunn asserts (1) OTC’s request for production of documents was improper and unauthorized by law, and (2) OTC’s audit of Dunn’s tax records represents an attempt by OTC to illegally and improperly expand and retroactively apply Oklahoma tax law. The record on appeal contains no statement of the underlying facts, and…