OPINION
EASTAUGH, Justice.
I. INTRODUCTION
This appeal raises questions about the tax payable under the Alaska Net Income Tax Act, AS 43.20.011-43.20.350 (ANITA), for tax years 1981 through 1988 on income derived by the taxpayer from domestic and foreign shipping operations and investments. The State of Alaska, Department of Revenue (DOR) assessed additional income taxes against the taxpayer, OSG Bulk Ships, Inc. The superior court...
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