OPINION
KELLEHER, Justice.
This is a statutory petition for certiorari which was initiated pursuant to the relevant provisions of the Administrative Procedures Act, G.L.1956 (1969 Reenactment) § 42-35-16. The petitioner is the Tax Administrator of the State of Rhode Island. He seeks a reversal of a Superior Court judgment which reversed his determination that as of February 23, 1973 the respondent owed a use tax which together with interest and penalties...
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