OPINION
O'BRIEN, Justice.
This action was commenced by Peterson Manufacturing Company as a claim for refund of excise and franchise taxes paid for the years 1984, 1985 and 1986, and for review of the denial of a request for a variance of the statutory apportionment formula for calculating the excise and franchise taxes paid by petitioner. The proceeding was initiated before the State of Tennessee Claims Commission and was removed to the Chancery Court for...
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