Heard Feb. 19, 1991.
Decided May 6, 1991.
Rehearing Denied Aug. 15, 1991.
TOAL, Justice:
This appeal arises out of a dispute between appellant South Carolina Tax Commission (Tax Commission) and respondents Collins Music Co., Inc. and Collins Novelty Co., Inc. (Collins) over the valuation of certain property as merchant's equipment pursuant to S.C. Code Ann. § 12-37-970.
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