HENNESSEY, C.J.
The taxpayers challenge a decision by the Appellate Tax Board (board) dismissing their appeal for lack of jurisdiction. On February 6, 1982, the taxpayers filed an application with the Commissioner of Revenue (Commissioner) for an abatement of their 1980 State income taxes. On January 27, 1983, they received a refund check which represented a partial abatement. The Commissioner claims this check was accompanied by a certificate explaining his decision...
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