OPINION
PAOLINO, Justice.
These consolidated cases are before us on appeal and on certiorari for a review of a Superior Court judgment affirming a decision of the respondent, the tax administrator. The respondent had assessed on each petitioner a use tax under G.L. 1956 (1970 Reenactment) § 44-18-20, as amended by P.L. 1967, ch. 179, art. 2, § 7, on modular home components each had purchased. After paying the amounts of the deficiencies, the petitioners...
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