On August 5, 2020, the Department issued an assessment to the Taxpayer for the tax periods from January 1, 2013 through December 31, 2017. The assessment included gross receipts tax, penalty, and interest. The Taxpayer argued that some of the services provided were for out-of-state customers but was unable to provide full records for all sales. For those transactions were the documentation showing entitlement to the deduction the Department abated that portion of the assessment. The hearing officer determined that the penalty and interest could also not be abated based on the facts of the protest and so the protest was denied.