GUNN, Judge.
The cause of this appeal is a compensating use tax assessed against Pipe Fabricators, Inc. (the taxpayer) on the purchase price of two helicopters and aircraft parts purchased outside Missouri. One helicopter was procured in California in June 1978; the other was purchased in Oklahoma in February 1979. The taxpayer paid no sales tax on either.
A use tax audit by the Department of Revenue resulted in an assessment on unpaid use tax of $8,987.84...
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