RICHARDSON, Chief Justice.
The issue on appeal is whether the taxpayer, Photo Management, Inc. (hereafter PMI) should be assessed at the lower excise tax rate of one-half of one percent or at the higher rate of four percent. The Tax Appeal Court ruled that the appropriate tax classification for PMI's photographing business was "wholesaling," taxable at the lower rate, rather than "service business or calling," taxable at the higher rate. After close review of the...
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