Assume Connecticut has passed a statute: (1) providing that internet sellers outside of Connecticut must collect Connecticut sales tax and remit it to Connecticut if they have more than 200 sales transactions of any amount in Connecticut per year even though such a seller has no place of business in Connecticut; and (2) allowing the Connecticut Department of Revenue (DOR) to adopt regulations in furtherance of this statute. The DOR promulgates a regulation providing that if DOR determines an out-of-state seller has conducted more than 200 such transactions within any year and not collected and remitted the sales tax to Connecticut, the DOR may send a tax deficiency notice to such a seller and there is no opportunity to challenge the tax determination by the DOR.

Is this statute and regulation constitutional? Please describe in detail why it is or is not constitutional