REIBER, C.J.
¶ 1. Taxpayers appeal a superior court decision granting State of Vermont Department of Taxes' summary judgment motion and thereby requiring taxpayers to pay the unpaid land gains tax pursuant to 32 V.S.A. § 10006. On appeal, taxpayers argue that the six-year statute of limitations in 32 V.S.A. § 5892 bars the Department from collecting the land gains tax, and challenge the merits of the underlying tax assessment. We affirm.
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