O'CONNOR, J.
After the plaintiff taxpayer filed its 1980 corporate excise tax return and after an audit, the Commissioner of Revenue (Commissioner) assessed the taxpayer an additional excise of $177,316 plus interest. In arriving at the additional assessment, the Commissioner used the "unitary business" approach. The taxpayer paid the additional assessment on August 11, 1983. On December 11, 1984, this court decided in Polaroid Corp. v. Commissioner of Revenue...
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