Jones v. Ragland

I agree with the majority opinion to the extent that it finds no basis in the record for assessing sales tax on the “sales for resale.” I also agree with that part of the opinion holding that the appellant owes sales tax for three years based on the receipts which he furnished the department. However, I do not agree with extending the three year statute of limitations or in upholding the arbitrary income tax assessment.

This is a clear case of overreaching on the part of the tax collectors. The conduct of the appellant in this case should be considered in light of his perception that the…