Oklahoma Code § 68-2208

Title 68. Revenue And Taxation: Refusal of railroad to comply with act, liability -
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Taxpayer estopped to question Commission's determination, when.
If any railroad company shall fail or refuse to make any report
required by this act, or shall fail or refuse to withhold and pay
the tax due from any such company within the time hereinbefore
provided, it shall be liable for the full amount of such tax,
penalty and costs of collection.
If any freight line company, equipment company or mercantile
company as hereinbefore defined, shall refuse or neglect to make any
reports required by this act, or shall refuse or neglect to permit
an examination of its books, records, accounts and papers upon
demand of the Tax Commission, or shall refuse or neglect to appear
before the said Commission in obedience to its citation or summons;
it shall be estopped to question or impeach the action or
determination of the said Commission or the validity of the tax
imposed hereunder.

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