ADKISSON, Chief Justice.
Appellee, K-Mart, is a retail discount chain operating seven stores in Arkansas. Appellant conducted a use and sales tax audit of K-Mart for the period of April 1, 1974, through December 31, 1977. This audit resulted in the assessment of a use tax deficiency of $17,280.13 and a sales tax deficiency of $55,475.89. Each sum includes interest and 10% penalty. K-Mart paid the assessed sums under protest and filed suit for refund under the procedure...
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