Flores v. Colorado Department of Revenue, State, Tax Division

Opinion by

Judge MARQUEZ.

The Colorado Department of Revenue appeals from an adverse judgment of the trial court construing certain provisions of § 39-21-101, et seq., C.R.S. (1982 Repl.Vol. 16B). We affirm.

The Department issued notices of jeopardy assessment and demand for immediate payment, pursuant to “Section 111, Article 21, Title 39 Colorado Revised Statutes of 1973” and dated December 6, 1988, to Marcella Juanita Flores, Marvin Flores, Tammy Jayne Rumsey, Martin Delgado Flores, and Lee James Flores, identified by the Department as a partnership (taxpayers), for collection of Colorado…