LEADBETTER, Judge.
Darlyce A. Silberman and Betty J. Larkin petition for review of an order of the Board of Finance and Revenue. The Board has filed an application for summary relief, claiming that the Commonwealth has a clear right to judgment as a matter of law. For purposes of this application, we will accept petitioners' statement of the facts.
On either April 17 or April 27, 1992,
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