Heard Oct. 17, 1988.
Decided Feb. 6, 1989.
FINNEY, Justice:
South Carolina National Bank (SCN), the successor in interest by way of merger to First National Bank of South Carolina (FNB), instituted this action to recover $166,921.22 in taxes, penalties and interest assessed pursuant to a ruling by the South Carolina Tax Commission (Commission) that S.C. Code Ann. § 12-54-80(2) (Cum. Supp. 1986) should be retroactively applied. The Circuit Court...
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