OPINION BY JUDGE DOYLE, February 29, 1984:
The Commonwealth of Pennsylvania, Department of Revenue (Department) brings this appeal from an order of the Court of Common Pleas of Philadelphia County which stayed proceedings in execution on a tax lien against the property of Appellee, Flaming Angus, Inc.
Flaming Angus, Inc. (Angus) was engaged in the retail restaurant business in the City of Philadelphia and in the course of that business collected sales taxes...
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