SHIVERS, Judge.
This is an appeal from final agency action of the Department of Revenue (Department), assessing a use tax and penalty against the appellant, United Engines, Inc. (United). We agree with the Department that the assessment was correct, and affirm.
In 1981, United, a Delaware corporation, entered into a joint venture with Broward Marine, Inc. of Fort Lauderdale, Florida for the construction of a prototype vessel with three marine engines instead...
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