WHITESIDE, J.
Appellant, Union Oil of California ("Union Oil"), appeals from a decision of the Board of Tax Appeals, which concluded that the fair market value of a shopping center owned by Union Oil was $1,280,000 on the tax lien date of January 1, 1982. Union Oil raises the following assignments of error:
"1. The Board of Tax Appeals' decision and order is unreasonable and unlawful because it erroneously found that the entire sum paid by Union Oil to Tempo...
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