BOURCIER, Justice.
This case comes before us on a petition for certiorari brought by R. Gary Clark, the state tax administrator, seeking review of a final judgment of the Sixth Division District Court, in favor of the respondent-taxpayers, Ronald and Shelley B. Knaggs (the Knaggs). A District Court judge found that the federal tax on excess golden parachute payments, contained in I.R.C. § 4999, was an excise tax and not an income...
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