SHORES, Justice.
Two cases were consolidated. The first case (hereinafter referred to as the tax case) arose from a complaint filed by the City of Birmingham, Alabama, on June 24, 1987, seeking delinquent license, sales, and occupational taxes and penalties from A & M Grocery, Inc., which is owned by David M. Shabani and Michael M. Shabani. The second case was filed by A & M Grocery and the Shabani brothers against Frank W. Lopez, the license and tax administrator...
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