PHILLIPS, Chief Justice.
Appellees brought this suit to recover certain franchise taxes paid under protest. All facts were stipulated. Trial was before the Court and resulted in judgment for Appellees in the full amount sought, $130,212.57 plus interest.
The tax involved is the additional tax imposed by Art. 12.20, Title 122A, Taxation-General, Vernon's Civil Statutes. Art. 12.20 provides in part as follows:
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