SHEEHY, Justice.
Billy M. and Bertie Froman (hereinafter referred to as the taxpayers) appealed the decision by the State Tax Appeal Board (hereinafter referred to as STAB) that the taxpayers failed to file the required election form with the Department of Revenue (DOR) for Production Systems, Inc. (PSI) to be treated as a small business corporation. The District Court, Ninth Judicial District, Glacier County upheld the decision by STAB. The taxpayers appealed the...
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