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Statement also indicates that, on November 15, 1995, the Board
recorded to petitioner’s tax account for 1993: (1) A $1,666
proposed assessment for that year which became final on that day,
and (2) $2,834 of penalties and $56.07 of interest for that year.
The Statement provides that, as of November 27, 1995, petitioner
owed the Board $2,860.23 in income tax, penalties, and interest
for its 1993 income tax year. Petitioner concludes from the
Statement that it owed the Board no income taxes from April 15,
1993, through November 15, 1995, and, hence, it should not have
been suspended between those dates.
We are unpersuaded by petitioner’s argument that its
suspension was improper either ab initio or beginning in 1993.
The certificate of the secretary of state provides clearly that
petitioner’s corporate powers, rights, and privileges were
suspended at least through the period from April 1, 1991, through
February 15, 2000, and the Board’s certificate of revivor states
just as clearly that petitioner’s rights, powers, and privileges
were only restored effective February 28, 2000. Petitioner does
not adequately dispute this prima facie evidence. Even assuming
that the certificate of the secretary of state is not conclusive,
an assumption that we make with much reservation, we give little
weight to petitioner’s bald assertion that it never received the
notice required under the statutory scheme. Nor do we believe
that the Statement supports petitioner’s assertion that it owed
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