CALKINS, J.
[¶ 1] Brent Leasing Co., Inc. appeals the judgment of the Superior Court (Kennebec County, Marden, J.) affirming a decision of the State Tax Assessor which denied it an exemption from the Maine Sales and Use Tax Law, 36 M.R.S.A. §§ 1751-2113 (1990 & Supp.2000). Brent Leasing argues that its vessel, the Friendship IV, is an instrumentality of foreign commerce and exempt from the use tax pursuant to 36 M.R.S.A. § 1760...
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