Delaware Code § 30-5220

Failure to pay tax; determination; redetermination; review
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(a) If any person shall fail to pay any tax imposed by this chapter for which the person is liable, the Secretary of Transportation is
authorized and empowered to make a determination of additional tax and interest due by such person based upon any information within
the Secretary's possession or that shall come into the Secretary's possession. All of such determinations shall be made so that notice
thereof shall reach the parties against whom made within 3 years after the due date of the tax.
(b) Promptly after the date of such determination, the Secretary of Transportation shall send, by certified mail, a copy thereof to the
person against whom it was made. Within 60 days after the date upon which the copy of any such determination was mailed, such person
may file with the Secretary of Transportation a petition for redetermination of such taxes. Every petition for redetermination shall state
specifically the reasons which the petitioner believes entitle the petitioner to such redetermination and it shall be supported by affidavit that
it is not made for the purpose of delay and that the facts set forth are true and correct. It shall be the duty of the Secretary of Transportation
within 90 days after the date of any determination to dispose of any petition for redetermination. Notice of the action taken upon any
petition for redetermination shall be given to the petitioner promptly after the date of redetermination by the Secretary of Transportation.
(c) Any person shall have the right to review by the Secretary of Transportation and appeal to the Superior Court of this State.

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