Campbell v. State, Department of Taxation

OPINION

This is a case of first impression. The appellants were charged with attempting to evade the payment of Nevada sales tax on the purchase of a 1990 Mercedes Benz in Reno, Nevada. Following unsuccessful appeals before an administrative hearing officer and the Nevada Tax Commission, the appellants paid the tax deficiency and brought a separate action against the State of Nevada in district court. The district court held that the appellants were barred from a second hearing on the merits, pursuant to the doctrine of administrative res judicata. For reasons stated herein, we reverse and…