LAY, Chief Judge.
Northern States Power Company filed suit in the district court for a refund of $108,231 paid in highway motor vehicle use tax assessments for the years 1972 through 1978. It challenged the Internal Revenue Service's assessment of approximately 500 utility trucks owned by it as tractor-trailer combinations rather than as single units. Northern claimed that its trucks should have been assessed as single units even though they are equipped for towing...
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