OPINION
PAOLINO, Justice.
Mart Realty, Inc. filed this petition for certiorari under G.L. 1956 (1969 Reenactment) § 42-35-16, to review a judgment entered by a justice of the Superior Court affirming a decision of the respondent tax administrator which upheld a tax assessed by the Rhode Island Division of Taxation against the petitioner. We granted the writ and pursuant thereto the pertinent records have been certified to this court.
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