FISHER, J.
First Chicago NBD Corp. f/k/a NBD Bancorp, Inc. and its many subsidiaries (hereinafter referred to collectively as NBD) challenge the Department of State Revenue's (Department) decision to assess NBD with additional Financial Institutions Tax (FIT) liability. See IND.CODE ANN. § 6-5.5-2-1 (West Supp.1998). NBD raises one issue for this Court's consideration:
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