Department of Revenue v. Citizens National Bank of Leesburg

GRIDLEY, W.C., Associate Judge.

The Department of Revenue (DOR) appeals the final order of summary judgment entered in favor of Citizens National Bank of Leesburg (bank). We affirm.

DOR is an executive agency charged with the responsibility and authority to administer and collect documentary stamp taxes.1 As part of its duties DOR is authorized to conduct examinations of tax*253payers’ records and make tax assessments based upon these examinations. In this case DOR issued a deficiency assessment to the bank based upon such an examination, concluding that the bank had failed to pay the correct…