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MONTANA DEPT. OF REVENUE v. DRAY

No. 93-588.

879 P.2d 651 (1994)

MONTANA DEPARTMENT OF REVENUE, Respondent and Appellant, v. Allan K. DRAY, Petitioner and Respondent.

Supreme Court of Montana.

Decided August 18, 1994.

Attorney(s) appearing for the Case

Lawrence G. Allen, Tax Counsel, State Depat. of Revenue, Helena, for appellant.

James P. Sites and Scott M. Heard, Crowley, Haughey, Hanson, Toole & Dietrich, Billings, for respondent.

TRIEWEILER, Justice.

Allan K. Dray petitioned the District Court for the First Judicial District in Lewis & Clark County for judicial review of an order of the State Tax Appeal Board which affirmed the Department of Revenue's (DOR) assessment of taxes, penalties, and interest against Dray. The District Court granted the petition for judicial review and reversed the decision of the State Tax Appeal Board. The DOR appeals the order of the District Court. We affirm...

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