JOHNSON, J.
The plaintiffs appeal the department of revenue administration's (the DRA) denial of their request for a tax refund. The issue presented is whether the distribution of unencumbered corporate assets to stockholders upon the corporation's dissolution and liquidation is a taxable event subject to a transfer tax pursuant to RSA 78-B:1, I (see Laws 1985, 407:1; current version at Supp. 1990).
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