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  5. 635 N.E.2d 1165 (1994)
 

SHOUP BUSES v. INDIANA DEPT. OF REVENUE

Nos. 45T10-9111-TA-00061, 45T10-9111-TA-00057, 45T10-9201-TA-00003.

635 N.E.2d 1165 (1994)

SHOUP BUSES, Inc., Tri-State Coach Lines, Inc., and United Limo, Inc., Petitioners, v. INDIANA Department of State Revenue, Respondent.

Tax Court of Indiana.

May 25, 1994.

Attorney(s) appearing for the Case

Morris A. Sunkel, Hoeppner, Wagner & Evans, Valparaiso, for petitioners.

Pamela Carter, Atty. Gen. of Indiana, Thomas K. Caldwell, Deputy Atty. Gen., Indianapolis, for respondent.

FISHER, Judge.

Shoup Buses, Inc., Tri-State Coach Lines, Inc., and United Limo, Inc. (collectively referred to as the Taxpayers) appeal the Indiana Department of State Revenue's (the Department) final determinations denying their claims for refund of Indiana Special Fuel Tax2 for the years 1986, 1987, 1988, and 1989.

ISSUE

The court phrases the issue in two parts:

A. Whether out-of-state contiguous counties...

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