OPINION
J. WOODFIN JONES, Chief Justice.
We withdraw our opinion and judgment dated August 31, 2009, and substitute the following opinion in place of the earlier one.
Appellant 7-Eleven, Inc. brought suit against Susan Combs, Comptroller of Public Accounts of the State of Texas, and Greg Abbott, Attorney General of the State of Texas (collectively, the "State") seeking a partial refund of sales tax that the Comptroller assessed on 7-Eleven...
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