DAY, Justice.
The Department of Revenue of the State of Colorado is in this court seeking to reverse a judgment of the trial court holding that Modern Trailer Sales is entitled to refund of sales taxes paid on certain installment sales of mobile homes. We will refer to the plaintiff in error, the Department of Revenue, as the Department, and to defendant in error as the Dealer. We hold the trial court erred, and reverse the judgment.
The facts are stipulated...
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