EBERHARDT, Judge.
Institutional Packers of America, Inc. (taxpayer) brought suit against the State Revenue Commissioner for refund of use taxes claimed to have been erroneously and illegally collected by the Commissioner on taxpayer's purchase of certain machinery. The petition alleges, inter alia, that taxpayer is engaged in the business of manufacturing and packaging food products for sale to distributors of such products to institutional customers. From April 1...
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