On October 9, 2019, the Department issued a notice of assessment for gross receipts taxes for reporting periods from January 1, 2012 to December 31, 2016. On November 1, 2019, the taxpayer filed a timely protest with the Department. The Taxpayer argued that the income in question on the federal Schedule C was not derived “from sale of goods or services” and therefore should not be subject to gross receipts tax. The Department argued that the Taxpayer had filed for a business tax registration certificate in 2008 and that the mismatch detected by the Department in income reported on the federal Schedule C and what was reported on the CRS-1 returns for the periods in question was evidence that the Taxpayer was underreporting the gross receipts. The Hearing Officer determined that the Taxpayer failed to meet the burden to show that the income in question was eligible for exemptions or deductions for the business income in question. For the forgoing reasons, the Taxpayer’s protest is denied.