Ryder v. Idaho State Tax Commission

SCHROEDER, Justice.

This is an appeal from the judgment of the Fourth District Court, which upheld a Notice of Deficiency issued by the Idaho State Tax Commission (Tax Commission) against Robert F. Ryder, dba Radio Paging Service (Radio Paging). The district court found that Ryder was liable for Idaho sales and use tax, plus penalties and interest, in the total amount of $48,789. Radio Paging appealed, and the Tax Commission cross-appealed the district court’s allowance of an offset for sales tax erroneously paid during the first four years of the audit period.

I

FACTS AND PROCEDURAL BACKGROUND

Ry…