Ex Parte Sonat, Inc.

We granted the petition of Sonat, Inc., for the writ of certiorari to review the judgment of the Court of Civil Appeals. The Jefferson Circuit Court had ordered the Alabama Department of Revenue (the "Department") to set aside its final assessment of Alabama corporate income tax against Sonat for the calendar year 1988 and to refund $12,153,702, plus interest, in Alabama corporate income tax collected from Sonat. The Court of Civil Appeals reversed that judgment. Alabama Dep't of Revenue v.Sonat, Inc., [Ms. 2960274, May 2, 1997] 752 So.2d 1206, (Ala.Civ.App. 1997). We reverse the judgment of…