NEELY, Justice:
In 1978 the State Tax Department audited the appellant, Teavee Oil & Gas Company, Inc., and assessed additional business and occupation tax in the amount of $50,237.86 against it for the period 1 January 1973 to 31 December 1977. The State Tax Commissioner disallowed the taxpayer's method for valuing its production of natural gas at the well mouth. On appeal to the Circuit Court of Kanawha County the tax commissioner's decision was affirmed
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