BRASWELL, Judge.
The underlying question of this case relates to ad valorem tax valuation for the year 1981 of Colonial Pipeline Company's system property in North Carolina. The North Carolina Department of Revenue established the valuation at $160,000,000, which is 13.162% of the whole system value of $1.216 billion. Colonial contends the true value is $127,956,000, which results mathematically in a difference of $32,044,000. Upon Colonial's appeal to the North Carolina...
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