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Sales and Use Tax Contested Tax Case Docket # 12 REV 02218 - 02/11/2013

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Issue: Whether Petitioner, as manager or REFS, LLC ("REFS"), is a responsible person for the sales and use tax liabilities incurred by REFS for the periods from December 1, 2009, through January 31, 2010, and March 1, 2010, through March 31, 2010 ("Periods at Issue").