ERVIN, Judge.
In these consolidated appeals, the Department of Revenue (Department) appeals a determination, pursuant to Section 120.56, Florida Statutes (1981), that a Department policy is an invalid rule, and American Telephone and Telegraph Company (AT & T) appeals from a final Department order, entered pursuant to Section 120.57, Florida Statutes (1981), in which assessments for corporate income tax deficiencies, totaling $1,138,158.00, were levied against...
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