Released for Publication by Order of the Court of Appeals of Oklahoma, Division No. 3.
OPINION
GARRETT, Vice Chief Judge:
Appellant, Phillips Petroleum Company (Phillips), appeals from an order of the Appellee. Oklahoma Tax Commission (OTC). The OTC order upheld the order of the Administrative Law Judge (ALJ) who held the statute of limitations, 68 O.S. 1981 [now 1991] § 223(a), did not...
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