OPINION BY JUDGE ROGERS, February 24, 1978:
C.I. Whitten Transfer Company (Whitten) has filed a petition for review of a decision of the Board of Finance and Revenue (Board) sustaining the Department of Revenue's refusal to resettle Whitten's corporate net income tax and a second petition for review of the Board's decision sustaining the Department's refusal to resettle Whitten's franchise tax. The petitions were consolidated for hearing and judgment herein.
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