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STATE DEPT. OF REV. v. UNION TANK CAR CO.

2050652.

974 So.2d 1024 (2007)

STATE DEPARTMENT OF REVENUE v. UNION TANK CAR COMPANY.

Court of Civil Appeals of Alabama.

Certiorari Denied June 15, 2007.

Attorney(s) appearing for the Case

Troy King, atty. gen., and Mark Griffin, asst. atty. gen., and asst. gen. counsel, Department of Revenue.

William B. Sellers and JoClaudia Moore of Balch & Bingham, LLP, Montgomery, for appellee.

Alabama Supreme Court 1061070.

PITTMAN, Judge.

The State Department of Revenue ("the Department") appeals from a summary judgment entered by the Montgomery Circuit Court in favor of Union Tank Car Company ("UTCC") in judicial-review proceedings concerning the correctness of an administrative determination that UTCC was not subject to Alabama income tax for the tax years 1994-1998.

The facts of this case are virtually undisputed. UTCC, a Delaware corporation...

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