OPINION
WEISBERGER, Justice.
These consolidated petitions for certiorari come before us to review two judgments of the District Court, one judgment (Hamilton and Bidlack) No. 88-192-M.P. favored the position of the tax administrator. The other judgment (Linnane) No. 87-478-M.P. favored the taxpayers. Since the taxpayers are the petitioners in the former and the tax administrator is the petitioner in the latter, we shall hereinafter refer to the parties as...
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