05/15/1998
P had not understood that she was subject to gross receipts tax and did not pay it for that reason. TP requested relief from assessment of gross receipts tax, penalty and interest in return for her agreement to pay future taxes after date of assessment. TP also requested relief from assessment because of financial hardship payment would cause. Held TP failed to overcome presumption of correctness of assessment and financial hardship is not grounds for abatement of assessment. Protest denied.