PITTMAN, Presiding Justice, for the Court:
STATEMENT OF THE CASE
¶ 1. This case arises on appeal, pursuant to Miss.Code Ann. § 27-25-23 (Supp.1999) and §§ 27-65-47 & -49 (1990), from a suit filed by OXY USA Inc. (OXY) against the Mississippi State Tax Commission (Commission) to recover improper severance taxes in the amount of $431,254.47, including interest and penalties. The assessment of severance taxes was appealed by OXY...
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