SMITH, Senior Judge.
The Department of Revenue (the Department, or DOR) appeals from that portion of a final summary judgment entered in favor of Kemper Investors Life Insurance Company (Kemper) finding that Kemper was entitled to a tax refund. Kemper, in turn, cross-appeals that portion of the final judgment ruling that it was not entitled to a refund of its payment of interest on an earlier assessed tax deficiency. For the following reasons, we affirm on appeal...
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