OPINION
FROEB, Judge.
Continental Bank filed claims with the Arizona Department of Revenue for tax refunds in the years 1974 and 1975. Both claims were denied by the Department and Continental timely protested to the Arizona State Board of Tax Appeals. The Board sustained the Department's position as to each claim for refund. Continental then filed civil actions for each taxable year in the superior court, which were consolidated. Both parties filed motions...
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