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EX PARTE STATE DEPT. OF REVENUE

1971747 and 1971761.

792 So.2d 380 (1999)

Ex parte STATE DEPARTMENT OF REVENUE and Ex parte Clay J. Calhoun. (Re State Department of Revenue v. Clay J. Calhoun and Clay J. Calhoun v. State Department of Revenue).

Supreme Court of Alabama.

July 23, 1999.

Attorney(s) appearing for the Case

Bill Pryor, atty. gen.; Ron Bowden, chief counsel, Department of Revenue, and asst. atty. gen.; and John Breckenridge, asst. counsel, Department of Revenue, and asst. atty. gen., for State Department of Revenue.

Gregory L. Leatherbury, Jr., and Bryan A. Thames of Hand Arendall, L.L.C., Mobile, for Clay J. Calhoun.

MADDOX, Justice.

These petitions for certiorari review involve tax assessments by the State Department of Revenue (the "Department"). They raise two issues:

(1) Should the provisions of §§ 40-2A-1 to -15, Ala.Code 1975, the "Alabama Taxpayers' Bill of Rights and Uniform Revenue Procedures Act" ("the Act"), be applied retroactively to a case that was pending before the Department when the Act was adopted? (2) Should the taxpayer, in whose...

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