OPINION
CONTRERAS, Judge.
This is an appeal from summary judgment granted Arizona Sand & Rock Co. (AS & R) in an action brought by the Arizona Department of Revenue (ADR) from a redetermination by the Board of Tax Appeals of AS & R's state tax deduction for federal income taxes paid for the fiscal years ending April 30, 1978, and April 30, 1979. Because we determine that AS & R followed the correct allocation formula in calculating its deduction...
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