dissenting.
I respectfully dissent to Division III. In my opinion, Code Ann. § 92-3402a (e) permits the Revenue Commissioner to collect sales tax from the purchaser where the seller disputes he received the tax and the commissioner has "reason to believe” the purchaser has not paid the tax. This leaves the purchaser and seller to resolve the controversy between them as to whether the purchaser paid the tax to the seller. The fact that the purchaser becomes a dealer when he fails to pay the tax does not affect his liability but merely imposes certain duties necessary for the effective administration of the Sales Tax Act.