OPINION BY JUDGE WILKINSON, JR., March 19, 1979:
These consolidated cases come before us on appeal from a decision of the Board of Finance and Revenue, divided three-two, refusing appellant's petitions for refund of 100 percent penalties assessed under Section 352(e) of the Tax Reform Code of 1971, Act of March 4, 1971, P.L. 6, as amended, added by Section 4 of the Act of August 31, 1971, P.L. 382, as amended, 72 P.S. § 7352(e), i.e., failure...
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