THOMPSON, Judge.
Medical Care Equipment, Inc. (hereinafter "MCE"), sells and leases durable medical equipment. The State Department of Revenue (hereinafter "the Department") assessed various State taxes, Talladega County taxes, and City of Sylacauga taxes against MCE for the period April 1988 through March 1991. MCE appealed that assessment to the Administrative Law Division, which conducted a hearing. On January 21, 1994, the Administrative Law Judge upheld the tax...
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