OPINION OF THE COURT
This is an appeal from summary judgment entered in favor of the Commonwealth in a tax collection case.
The Commonwealth brought suit against Koscot Interplanetary, Inc., the movant corporation, for unpaid 1977 and 1978 sales taxes. The corporation counterclaimed demanding a refund of any tax paid to the Commonwealth since 1973.
Upon the Commonwealth's motion for summary judgment, based on the movant's failure to utilize administrative...
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