OPINION
KLEINSCHMIDT, Judge.
Walter E. Heller Western, Inc. appeals from a summary judgment entered against it in its suit challenging the Department of Revenue's calculation of Heller Western's income tax liability for the calendar years 1976 through 1979. Under the applicable tax regulation if a greater proportion of a taxpayer's income producing activity with regard to sales of intangible property occurs outside the state, such sales are deemed not to have...
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