Belcher Oil Co. v. State, Department of Revenue

LARRY G. SMITH, Judge.

Belcher Oil Company appeals the Department of Revenue’s order assessing a tax deficiency, penalties and interest, under taxing statutes relating to sales of special fuels, Section 206.87(1), Florida Statutes (1975). Belcher Oil contends (1) that the sales were exempt from taxation; (2) that the Department’s rule requiring Belcher to *794obtain an exemption or resale certificate from its purchaser to receive the exemption, is invalid; (3) that the Department’s assessment of penalties is invalid because of the absence of fraudulent or intentional nonpayment; (4) that the…