STUMBO, Judge:
The Revenue Cabinet of the Commonwealth of Kentucky, the appellant, disagrees with a decision of the Franklin Circuit Court that awarded a deduction for most of the Michigan Single Business Tax (MSBT) paid by General Motors Corporation (GMC), the appellee. The appellee cross-appeals the same decision to the extent they were denied a total deduction for all amounts of the MSBT paid. We affirm the decision of the circuit court on both counts.
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