BRADLEY, Judge.
The Department of Revenue of the State of Alabama (hereinafter referred to as State) on June 13, 1963 made a final assessment of state income taxes against Gulf Oil Corporation (hereinafter referred to as Gulf) in the amount of $45,146.57 for the calendar year 1959.
The deficiency assessment of state income taxes resulted from a transaction involving the sale by Gulf of certain of its interests in the Citronelle, Alabama oil fields to Bart...
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