WORKMAN, Justice:
This case is before the Court based upon the appeal of Frederick Williams, Tax Commissioner of the State of West Virginia (hereinafter sometimes referred to as the "Commissioner"), from the May 17, 1994, final order of the Circuit Court of Cabell County, which reversed the Commissioner's September 23, 1991, administrative decision and ordered that tax refunds be paid to the Appellees, Robert L. Bradley and Nedra S. Bradley,
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