PER CURIAM.
Respondent disallowed petitioners' claimed credit on their 1980 and 1981 state income taxes for the severance taxes Shell Oil Company, petitioners' lessee, withheld from their royalty payments and paid to the state. Petitioners appealed the disallowance to the Michigan Tax Tribunal, whose hearing officer proposed an order dismissing their appeal. Petitioners now appeal as of right from the tribunal's judgment adopting the proposed order. We affirm.
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