McDONOUGH, Justice:
This is a proceeding to review a deficiency sales and use tax assessed to plaintiff by the State Tax Commission. The sum in dispute is $33,219.96 in sales taxes and $251.82 in use tax, including penalty and interest, totalling $40,371.13.
The facts of this proceeding are not in dispute. Plaintiff is a subsidiary corporation of the Union Pacific Railroad Company and the Southern Pacific Company, each of which own 50% of the capital stock...
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