ORDER ON PARTIES' CROSS-MOTIONS FOR SUMMARY JUDGMENT
FISHER, J.
Norrell Services, Inc. (Norrell) appeals the Indiana Department of State Revenue's (Department) imposition of Indiana gross income tax on franchise fees Norrell received during the years ending November 1, 1992, October 31, 1993, and October 31, 1994 (the years at issue). The matter is currently before the Court on the parties' cross-motions for summary judgment.
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