SMITH, Judge.
The Director of Revenue appeals from a decision of the Administrative Hearing Commission that the taxpayer, Franco, was entitled to a refund of use tax paid. We reverse.
The facts were stipulated. In March 1977, Franco executed a lease agreement with Allstate Leasing for rental of a Cadillac Seville. The rental agreement was executed in Maryland. In addition to his $311 monthly rental Franco agreed to pay Allstate $12 monthly for sales and use...
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