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A state appeals court in Sacramento, Calif., last month upheld a trial court ruling that a 0.25-cent hike in the sales tax enacted in 1991 to support San Francisco's schools and community colleges is invalid, opening the way for city businesses to seek refunds.

The increase was invalid because it was approved by only 55 percent of the city's voters, the court said. Under Proposition 13, a 1978 California tax-limitation initiative, the proposed tax required approval by a two-thirds majority of voters. Although the tax was approved by a two-thirds majority in a new vote last year, the court ruled that retailers who paid more than $5,000 in sales taxes during the 15 months between the original and second votes are eligible for refunds.

However, the city's schools and community college district have spent all but $1.5 million of the $25 million collected under the tax between 1991 and 1993. A lawyer for the San Francisco Educational Financing Agency said that no businesses have filed claims for refunds in the year since the original trial court ruling and that he does not anticipate any will do so now.

Rifle Project Ricochets: After a showdown between the National Rifle Association and organizers of a San Diego science fair, a 12-year-old boy's science project will appear in the fair after being temporarily banned.

Russ Grisbeck impressed his teacher in rural Ramona, Calif., with an experiment using a rifle to test how different amounts of gunpowder affect the speed and accuracy of bullets. Organizers of the privately run Greater San Diego Science and Engineering Fair, scheduled to open this week, worried, however, that the project might conjure up other gun-use ideas among youths.

But after a flare-up between the N.R.A. and organizers, fair officials decided last week to include Russ's project, which analyzes the results of the ballistics test he conducted with his father's supervision.

Russ is to be the guest of honor at a southern California gun show after the fair closes.

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