BRADY, Justice.
This is an appeal by the State Comptroller, Bob Bullock, from a summary judgment of the trial court in favor of appellee, Mel Powers, for refund of sales tax on the purchase of a Jet Commander aircraft. The aircraft was acquired by appellee for the purpose of commencing a charter service to carry persons or property. As a result of an audit by the Comptroller, a tax was assessed against the appellee in the sum of $26,557.53 on the Jet Commander aircraft...
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