DeBRULER, Justice.
On September 22, 1986, appellant William Ball filed a claim for refund with the Indiana Department of Revenue seeking reimbursement of $202,167.37. The Tax Court of Indiana, however, found for the Indiana Department of Revenue, hereinafter referred to as the Department, and ordered that appellant take nothing pursuant to his claim for refund. Ball v. Indiana Dept. of Revenue (1988), Ind.Tax,
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