Key legal question
Whether the transfer-tax assessment had to be served on the buyers rather than only on the sellers appointed as their representatives.
Extracted holding
Service on the sellers was valid because the purchase contract expressly authorized them to receive the assessment and invoice and to act in the tax proceedings for the buyers.
Extracted reasoning
The contract clearly appointed the sellers as representatives for the transfer-tax matter; the later objection decision cured the initial misdesignation by expressly naming the buyers as the taxpayers, represented by the sellers and their lawyer. The buyers therefore suffered no procedural prejudice.