RICHARDSON, Chief Judge.
The taxpayer, Puna Sugar Company, Limited (hereinafter, Puna Sugar), is a Hawaii corporation engaged in the business of producing and refining sugar in the Puna District on the Island of Hawaii. In 1969 Puna Sugar purchased boiler and diffuser equipment from unlicensed mainland sellers and imported the purchased equipment to the State for use in its Puna Sugar mill. The purchase price of the equipment was $990,771.06 and the freight charges...
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