Heard May 7, 1990.
Decided July 31, 1990.
Per Curiam:
This action was commenced by federal retirees against the State of South Carolina and the South Carolina Tax Commission (hereafter, collectively referred to as the "State") on April 4, 1989. The action was brought because of a March 28, 1989 United States Supreme Court decision, Davis v. Michigan Dept. of Treasury,
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