MERRILL, Justice.
This is an appeal from a final decree setting aside an attempted assessment of license tax by the State Department of Revenue under the provisions of Tit. 51, § 178, Code 1940, against Southern Electric Generating Co., hereinafter called SEGCO.
The pertinent part of Tit. 51, § 178, provides: "Each person, firm or corporation operating an electric or hydroelectric public utility shall pay to the state a license tax equal to four...
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