OPINION
WOOD, Chief Judge.
This direct appeal from the Decision and Order of the Commissioner of Revenue involves the liability of the taxpayer for gross receipts and municipal taxes, and interest on the gross receipts tax, for the period January 1, 1969, to November 30, 1971. The taxpayer claims it is not liable because of a statutory exemption. This exemption, Laws 1966, ch. 47, § 12(y) and Laws 1969, ch. 144, § 32, is compiled as § 72-16A...
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