REILLY, J.
Plaintiff-appellee, city of Cleveland, filed a complaint for declaratory judgment alleging that defendants-appellants, the Industrial Commission and the Administrator of the Bureau of Workers' Compensation, assessed $3,072,724.74 in workers' compensation premiums against it without authority. Defendants filed their answer in due course. The parties entered a Stipulation of Facts, which quoted in part as follows:
"3. At all times material herein...
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