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(a) If a taxpayer refuses or fails to comply in whole or in part with a request to provide records authorized by Section ___-555, the Tax Collector may issue his written Administrative Request which shall:
(1) designate the individual to provide information.
(2) describe specifically or generally the information to be provided, and any documents sought to be examined.
(3) state the date, time, and place in which the individual shall appear before the Tax Collector to provide the information and to produce the documents sought.
(4) be directed to:
(A) any director, officer, employee, agent, or representative of the person sought to be examined; or
(B) any independent accountant, accounting firm, bookkeeping or financial service retained or employed by such person for any purpose connected with business activity subject to taxation; or
(C) any other person who, in the opinion of the Tax Collector, has knowledge of factsbearing upon any tax liability of the person or taxpayer from whom information is sought.
(b) The failure of a taxpayer to comply with reasonable requests for records without good reason or cause may, in the exercise of judicial discretion by a court, be held to constitute a failure to exhaust administrative remedies.