CORDY, J.
The Sherwin-Williams Company (Sherwin-Williams) appealed from a decision of the Appellate Tax Board (board) upholding the denial by the Commissioner of Revenue (commissioner) of its request to abate $59,445.40 in corporate excise taxes assessed for tax year 1991, and we transferred the case to this court on our own motion. The contested assessment was the result of the commissioner's disallowance of approximately $47 million that Sherwin-Williams had deducted...
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