Johnson, Bernard E., "Sales and Use Tax Compliance: Redefining the Relationship Between States and Taxpayers", Proceedings of State and Local Tax Institute, (Washington, DC: Georgetown University Law Center, Continuing Legal Education Division, May 16-17, 1996), pp. 319-340.
Ohio Revenue Code sec. 5739.13. (Authorizes Ohio revenue commission to use sample of vendor's sales and consumer's purchases in a tax audit). Ohio Revenue Code sec. 5741.13. Ohio Administrative Code sec. 5703-9-02.
Cherry Street Corp. v. Porterfield, 27 Ohio St. 2d 260 (Ohio 1971). Dunhall Pharmaceuticals, Inc. v. Tracy, Case No. 94-T-1340 - Ohio Board of Tax Appeals, 1995) (Board held that to successfully challenge an audit based on a test check the taxpayer must show that the selected test check period is not representative of normal business conditions). Lubrizol Corporation v. Tracy, Case No. 94-L-151, 1195 Ohio App. LEXIS 3092,1995 WL 453125. (Court held that Ohio statute expresses authorizes sampling even when the taxpayer has all records available for a a complete audit. The taxpayer was given an opportunity to participate in the audit planning, and cannot challenge the auditor's account selection after the completion of the audit. The commission is not required to find and correct errors that result in a refund to the taxpayer). Narmac, Inc. v. Tracy, 66 Ohio St. 3d 637, 614 NE.2d 1042 (Ohio 1993). Quality Food and Vending Co. v. Lindley, (Ohio 1985).