LEWIS, J.:
In 1990, the Sedgwick County Appraiser began a series of personal tax audits designed to discover personal property which had "escaped taxation." One of the audits conducted was of the Dillon Stores (taxpayer). When that audit was completed and the information was computed, the total amount assessed to the taxpayer for the years 1986 to 1992 was approximately $2.9 million. The case has arrived at this juncture by way of an appeal and cross-appeal from the...
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