KARWACKI, Judge.
Between 1980 and 1983, appellants Disclosure, Inc. (DI) and National Standards Association (NSA), and Disclosure Partners (DP), the predecessor to appellant Disclosure Information Group, purchased all or substantially all of the assets of four businesses. The Retail Sales Tax Division of the Comptroller of the Treasury levied sales tax assessments against the appellants in connection with those transactions as follows:
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