OPINION
RABINOWITZ, Justice.
I. INTRODUCTION.
National Bank of Alaska (NBA) appeals from the superior court's affirmance of the Department of Revenue's (DOR) decision to deny its request for a tax refund. The refund was sought for an alleged overpayment made in 1981 under the Alaska business license (ABL) tax imposed by AS 43.70.030.
NBA is a national banking association with its principal place of business in Anchorage, Alaska. In 1981...
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