KIDD, Justice.
Appellant Borden, Inc. sought a franchise tax refund for tax year 1982, which appellee John Sharp, Comptroller of Public Accounts ("Comptroller") denied. The district court subsequently granted the Comptroller's motion for summary judgment and denied Borden's motion for summary judgment, holding that limitations barred Borden's claim. Borden appeals, arguing that the plain language of the contested statute supports its contention that limitations had...
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