PRATHER, Presiding Justice, for the Court:
I. STATEMENT OF THE CASE
¶ 1. Following an audit of Lady Forest Farms, Inc. (LFF), the Mississippi State Tax Commission (MSTC) assessed LFF with a total of $47,079.50 in additional taxes, $8,945.14 in interest, and $4,707.95 in penalties for an alleged underpayment of state franchise taxes by said corporation during the fiscal years 1989 and 1990. LFF appealed to the MSTC Board of Review...
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