COMBS, Justice (dissenting).
I am unable to find anything in the Act, or in the history of the Act, to justify the conclusion reached by the majority. It seems clear to me that it was the intention of the Legislature to classify employers according to the number of positions of employment, rather than by the number of persons employed to fill those positions.
This is a taxing statute and the rule is that any ambiguity will be construed against the taxing authority...
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