McHUGH, Justice.
This is an appeal by the State Tax Commissioner (hereinafter the "Commissioner" or the "appellant") from a final order of the Circuit Court of Mingo County, entered on August 6, 1979, which affirmed in part and reversed in part the Commissioner's administrative decision of October 29, 1976, which had upheld a Business and Occupation Tax delinquency assessment against appellee, Gilbert Imported Hardwoods, Inc. (hereinafter "Gilbert" or the "appellee...
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