NAHRA, Presiding Judge.
This appeal arises from the decision of the Board of Tax Appeals ("BTA") reversing the Tax Commissioner's determination that Carnegie Capital Management Co. ("Carnegie"), appellee, was not entitled to a refund of corporation franchise taxes for the tax years 1982, 1983 and 1984.
During the period January 1, 1981 through January 1, 1984, Carnegie, an Ohio corporation, maintained an office in Cleveland, Ohio, from which it engaged in...
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