LILLIE, J.
Plaintiff, a California corporation, brought this action for the recovery of sales taxes paid under protest. The gross receipts, the subject of the tax, were derived from the sale of three aircraft by plaintiff to two foreign corporations. The facts not being in dispute, the sole issue involves the applicability of a statute which provides for the exemption from taxation of the gross receipts of aircraft "sold to persons who are not residents of this State...
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