BISHOP, Judge.
United Parcel, Inc. (UPS or appellant) filed claims for refunds of Maryland sales and use taxes that it alleges to have paid erroneously for the period January 1, 1977 through July 31, 1980. The Comptroller of the Treasury, Retail and Sales Tax Division (Comptroller or appellee), refused to refund $98,363.68 of UPS's claims and then on September 24, 1980 assessed an additional $38,181.77 for unpaid sales and use taxes plus penalty and accrued interest...
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