OPINION
PER CURIAM:
This tax refund action comes before the court on plaintiff's and defendant's exceptions and briefs to the recommended decision of Senior Trial Judge Mastin G. White, which he has submitted in accordance with Rule 134(h) on August 25, 1976. Neither party has taken exception to any of the trial judge's proposed findings of fact; however, both parties have taken exception to the trial judge's recommended conclusion of law. Upon consideration...
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