SAM A. BEATTY, Retired Justice.
The Department of Revenue of the State of Alabama ("the Department") appeals from a summary judgment entered in favor of Magnolia Methane Corporation. We affirm.
Magnolia Methane is a Delaware corporation. It is wholly owned by Transco Resources, Inc., a Delaware corporation (its corporate parent). Transco Resources is wholly owned by Transco Energy Company, a Delaware corporation (Magnolia Methane's corporate grandparent)....
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