Plaintiff, Giffels Associates, Inc., filed annual reports and paid franchise fees for the years 1968 to 1971. The reports were accepted by defendant. In 1973, defendant conducted a field audit of plaintiff's books and assessed a franchise fee deficiency of $49,585.29, including interest, for the years 1968-1971, which was paid under protest. Two years later, in Clark Equipment Co v Department of Treasury...
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