OPINION
DROWOTA, Justice.
This tax litigation involves an appeal by the State of Tennessee and the Tennessee Department of Employment Security, Defendants-Appellants, from an order of the Tennessee Claims Commission requiring the State to refund employment security taxes that The Beare Company, Claimant-Appellee, paid to the Tennessee Department of Employment Security for the period 1982-86. The taxes were assessed against Beare by the State in 1987 after...
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