FISHER, Judge.
Bethlehem Steel Corporation (Bethlehem) claims a refund from the Indiana Department of State Revenue (the Department) of gross income tax assessed and collected together with interest on cash proceeds received from interstate transactions structured pursuant to Internal Revenue Code § 168(f)(8) (1981) (repealed 1986) in the amount of $717,451 for the years 1981, 1982, and 1983. The case is before the court on the parties' cross motions for summary...
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