FISHER, J.
Petitioner Salin Bancshares, Inc. (Salin) appeals the Indiana Department of State Revenue's (Department) final determination denying Salin's requested refund of Financial Institutions Tax (FIT), see IND. CODE ANN. § 6-5.5-1-1 to -9-5 (West 2000), for the 1991 tax year. In this original tax appeal, Salin alleges that the Department's assessment of the FIT was
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