State v. Tunkey

Summary

The court held that the Arizona Department of Revenue was not required to make a separate personal assessment against a responsible person before suing to collect transaction privilege taxes that the taxpayer-business had self-assessed but failed to remit. The four-year notice period applies to additional taxes arising from unreported or underreported liability, not to the same amounts already reported and self-assessed by the business. The court therefore affirmed the judgment imposing liability on Tunkey.