Silver State Electric Supply Co. v. State ex rel. Department of Taxation

OPINION1

By the Court, Gibbons, J.:

In this appeal, we consider whether NAC 360.452 exceeds the scope of NRS Chapter 360. NRS 360.395 directs a person to pay a tax determination amount before seeking judicial review of a final Nevada Tax Commission decision. In lieu of immediately paying the determination amount, however, NRS 360.395 allows the entity to enter into an agreement to pay that amount at a later date. The type of agreement permitted under this statute is further described by regulation, NAC 360.452. NAC 360.452(1) provides that the agreement must be in writing, personally guaranteed…