Video Stop, Inc. v. Arizona Department of Economic Security

*2OPINION

FIDEL, Presiding Judge.

Video Stop, Inc., the successor to the business of another, appeals from a decision of the Arizona Department of Economic Security (“DES”) Unemployment Insurance Appeals Board imposing liability for unpaid principal, penalties, and interest on unemployment taxes that its predecessor owed. We hold that the appeals board erred when it found that DES had made a timely determination of contributions, interest, and penalties that were due.

Our holding rests on the distinction between two letters that DES sent to Video Stop. The first, dated November 19, 1987, and…