SIMONETT, Justice.
Lee and Sandra Guilliams filed state income tax returns for 1975 and 1976, reporting no tax for 1975 and $175.13 for 1976. After an audit, the Commissioner of Revenue issued his assessment order of August 28, 1978, finding that the taxpayers should have applied the farm loss modification law, which limits the amount of farm loss a taxpayer may offset against nonfarm income, and assessed a tax of $587.65 on the first return and $766.65 on the second...
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