MEMORANDUM OPINION
J. WOODFIN JONES, Chief Justice.
Bell Helicopter Textron, Inc. ("Bell") appeals a take-nothing judgment in a sales and use tax refund suit under Chapters 112 and 151 of the Texas Tax Code. Tex. Tax Code Ann. §§ 112.001-.156, 151.001-.802 (West 2008 & Supp. 2011).
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