NEWBERN, Justice.
Couey Chrysler-Plymouth, Inc., (Couey) the appellee, brought suit in chancery court challenging a gross receipts tax jeopardy assessment made by the appellants. The appellants, referred to here collectively as the state, are Mahlon Martin, Director of the Arkansas Department of Finance and Administration, Jim Pledger, Commissioner of Revenues, and George Stepps, District Manager of the Office of Field Audit. The state counter-claimed, alleging Couey...
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