Fowler v. Strickland

Marshall, Justice.

The appellant taxpayer is engaged in the retail sale of tangible personal property. He is classified as a "dealer” under the Georgia Retailers’ and Consumers’ Sales and Use Tax Act (Ga. L. 1951, pp. 360, 362; Code Ch. 92-34A). See Code Ann. § 92-3404a. (Citations to the Sales and Use Tax Act will be given by Code section.)

In 1968, the appellant ceased collecting sales taxes and remitting them to the state.1 He also ceased filing tax returns.2 An audit investigation by the appellee State Revenue Commissioner was later begun, but the appellant refused to provide the…