Supreme Court of Alabama November 21, 2012, 1111190 (State Department of Revenue v. HealthSouth Corp.)

STUART, Justice.

The State of Alabama Department of Revenue (“the Department”) petitioned this Court for a writ of certiorari to review the Court of Civil Appeals’ no-opinion af-firmance of the circuit court’s judgment awarding HealthSouth Corporation and related entities (hereinafter referred to collectively as “HealthSouth”) refunds of Alabama income tax it had overpaid for the 1996, 1997, and