OPINION
HERNANDEZ, Judge.
This is an appeal from the Decision and Order of the Revenue Division of the Taxation and Revenue Department (Department) denying Getty Oil Company's (Getty) requested abatement of part of its state income taxes assessed for the calendar years 1972, 1973, and 1974.
Getty is an international company engaged in oil and gas exploration and production, and is also the parent company of a number of wholly-owned subsidiary companies...
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