MURPHY, P.J.
Petitioner appeals as of right the decision of the Michigan Tax Tribunal in favor of respondent. The Tax Tribunal denied petitioner's claim that the exemption in the severance tax act, MCL 205.315; MSA 7.365, entitled petitioner to a refund of the payments made under the Single Business Tax Act, MCL 208.1 et seq.; MSA 7.558(1) et seq. The Tax Tribunal also affirmed respondent's assessment of penalties and interest for underpayment and late...
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