Section 350-52-010 - DEFICIENCY DOCUMENTARY STAMP TAX PAYMENT010.01 In the event that the Department of Revenue has reason to believe that an exemption was improperly allowed or that the consideration stated was less than current market value as determined in accordance with these regulations, the Department of Revenue shall investigate the transaction to determine if tax is due. Should the Department of Revenue determine that tax is due, it shall issue a Notice of Deficiency Determination to the grantor. The grantor will be allowed to protest the deficiency determination within thirty days of its issuance. Should the grantor file a protest to the Notice of Deficiency Determination, the Department of Revenue shall hold a hearing under the Administrative Procedures Act to determine the correct tax and collect the same. Should the grantor fail to protest the Notice of Deficiency Determination within thirty days, the Department of Revenue shall immediately proceed to collect the same. When the Department of Revenue has issued a deficiency determination, the register of deeds shall not be permitted a percentage of the proceeds thereafter collected by the Department.350 Neb. Admin. Code, ch. 52, § 010