OPINION
NIX, Chief Justice.
This action arose when appellant, Hospital Utilization Project ("HUP"), filed a petition for refund of sales and use taxes with the Board of Appeals of the Department of Revenue on June 16, 1980, following a determination by the Department of Revenue that HUP was not entitled to a charitable exemption from imposition of the taxes. In early December, 1980, the Board of Appeals concluded that...
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