ROBERTSON, Judge.
Taxpayer, St. Louis Southwestern Railway Company (hereafter "taxpayer"), appeals from a judgment of the circuit court affirming the decision of the State Tax Commission (hereafter "the Commission"), denying taxpayer leave to amend its petition for review of a franchise tax determination. At issue are the procedural requirements for obtaining a refund of state taxes. This case, therefore, involves the construction of the revenue laws of this state...
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