FISHER, Judge.
The Petitioner, Scott Oil Company, Inc. (Scott Oil), moves for summary judgment on its appeal challenging the Indiana Department of State Revenue's (the Department) assessment and collection of special fuel tax for the years 1985, 1986, and 1987. On September 20, 1989, Scott Oil paid the assessed tax together with interest and penalties in the amount of $30,879.84 and simultaneously filed a claim for refund, which the Department has neither granted...
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