STOCKARD, Commissioner.
The City of Springfield, a municipal corporation, brought this action in two counts; Count I for the return of taxes paid under protest, and Count II for the cancellation of a penalty for the late payment of the tax.
Springfield owns, and operates by use of a Board of Public Utilities, all of its utilities, including electric, gas, water, and transportation services. The Board procures insurance on substantially all facets of its operations...
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