Taxation And Revenue Department V. Bien Mur Indian Market Center Inc‪.‬

The Department argues that, because the language of the statute does not contain such a requirement, the court of appeals erred in conditioning application of Section 7-1-18(D) on the culpability of the taxpayer. We agree with the Department that application of Section 7-1-18(D) does not turn on the taxpayer's culpability and we hold the court of appeals erred in precluding the Department from applying the longer assessment period under the facts of this case.