Per Curiam.
First, on the commissioner's appeal, the commissioner argues that the BTA's analysis of the permissive tax procedures is incorrect and, alternatively, that CNG did not overcome its burden to establish the extent of her error by showing where the sales occurred. We disagree with the commissioner that the BTA misanalyzed the permissive tax procedures, but agree that CNG did not establish the extent of the commissioner's error.
Under R.C. Chapters...
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