BAKES, Chief Justice.
Appellants Willard and Patricia Hamilton (taxpayers) are non-resident Idaho taxpayers residing in Clarkston, Washington. The taxpayers were audited and a deficiency determination was issued against them. The taxpayers paid the deficiency and filed a protest with the Idaho State Tax Commission, arguing that the allocation formula used by the Tax Commission was incorrect. The Tax Commission reconfirmed the allocation formula it had used. The taxpayers...
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