GM admits that it owes additional tax due to the federal adjustments and that R.C. 5733.12 bars refund since its claim is not timely. Moreover, the commissioner admits, without admitting that the instant interest income is not taxable, that interest from federal obligations is not taxable.
GM, however, argues, in Proposition of Law No. 1, that R.C. 5733.031(C) requires it to file complete amended...
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