At the time the Department began a field audit of the taxpayer in July 2001, the auditor delivered a notice giving the taxpayer 60 days to obtain possession of any nontaxable transaction certificates (NTTCs) needed to supports its deductions. The Department subsequently assessed the taxpayer for gross receipts tax, penalty, and interest on the receipts for which no NTTCs were provided. The taxpayer protested the assessments, arguing that several of its customers were either unwilling or unable to provide the taxpayer with NTTCs. The protest was denied because the taxpayer was statutorily required to pay gross receipts tax on receipts from transactions for which the taxpayer did not have an NTTC.
Century Glass, Inc.