OPINION
LEE ANN DAUPHINOT, Justice.
In this case Appellant, A & S Air Service, Inc. ("A & S"), seeks a refund from Appellees, Denton County Appraisal District ("DCAD") and Denton County Appraisal Review Board ("DCARB"), arguing that the DCAD failed to allocate the value of a business aircraft to reflect use in interstate commerce according to section 25.25(c)(3) of the Texas Tax Code ("the Tax Code").
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