LOBRANO, Judge.
This appeal arises out of an action originally brought by Bean Contracting Co., now C.F. Bean Corporation (Bean), against Shirley McNamara in her capacity as Secretary of the Department of Revenue and Taxation, State of Louisiana (State). Bean is disputing an assessment of Louisiana income taxes on the sale of two of its vessels. According to Bean, the vessels were sold in international waters and should not have been taxed in Louisiana.
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