OPINION
RABINOWITZ, Justice.
This appeal challenges the Department of Revenue's decision to assess additional taxes against the appellants under the Alaska Business License Act (ABLA) for the years 1972 through 1977.
I. FACTUAL AND PROCEDURAL BACKGROUND
Each taxpayer had entered into a contract with Alyeska Pipeline Service Company ("Alyeska") to supply materials to and assist Alyeska in the construction of the Trans-Alaska Pipeline System...
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