SABERS, Justice.
Department of Revenue assessed taxpayer for delinquent sales taxes, penalty, and interest based upon the retroactive application of a statute of limitations or, alternatively, a finding of fraud. Taxpayer appeals. We affirm on fraud.
FACTS
As a result of a routine canvass of Winner, South Dakota, by the Department of Revenue (Department) on December 28th and 29th, 1988, the Department determined that John J. Simpson (Simpson) failed...
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