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COM. EX REL. ATTY. GEN. v. WASH. GAS LIGHT CO.

Record No. 800131.

269 S.E.2d 820 (1980)

COMMONWEALTH of Virginia ex rel. ATTORNEY GENERAL of Virginia v. WASHINGTON GAS LIGHT COMPANY and State Corporation Commission.

Supreme Court of Virginia.

August 28, 1980.

Attorney(s) appearing for the Case

Norman K. Marshall, Asst. Atty. Gen. (Marshall Coleman, Atty. Gen., John G. MacConnell, Kenneth W. Thorson, Asst. Attys. Gen., on briefs), for appellant.

John W. Riely, Lewis S. Minter, Richmond (Lewis Carroll, Edward L. Flippen, Richmond, Carl W. Belcher, Douglas V. Pope, Washington, D.C., Hunton & Williams, Richmond, on briefs), for appellees.

Before I'ANSON, C. J., and CARRICO, HARRISON, COCHRAN, POFF, COMPTON and THOMPSON, JJ.

POFF, Justice.

On this appeal, we review an order of the State Corporation Commission sitting as a trial court, Code § 58-1124. The order granted a petition filed under Code § 58-1122 by Washington Gas Light Company (WGL), a public utility as defined by Code § 56-232. The petition alleged that certain taxes paid under Code §§ 58-603 and -661 (collectively, gross receipts taxes) had been erroneously assessed upon WGL's revenue from five "spot...

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