LEAPHART, Justice.
The Montana Department of Revenue (Department) assessed taxes, interest and penalty against the appellant, Jack G. Pletcher (Pletcher), for Montana income earned from his employment in Alaska during the years 1982 through 1992. Pletcher appealed the assessment to the State Tax Appeal Board (STAB), which ruled that he was a resident of Montana for income tax purposes during that period of time. Pursuant to the Montana Administrative Procedure Act...
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