BENHAM, Justice.
Pursuant to Regulation 560-12-2-.84 (7) (b) of the Rules and Regulations of the Georgia Department of Revenue, appellant State Commissioner issued a tax assessment of $18,765.18 against appellee Adam Cab for failure to remit sales tax on fares for transportation for January through November 1986. We granted the Commissioner's application for discretionary review of the denial of his motion for summary judgment to determine...
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