FISHER, Judge.
Thomas Dodge of Highland, Inc. ("Thomas Dodge") petitions the court to set aside a final determination of the State Board of Tax Commissioners ("the Board"). Thomas Dodge challenges first, the Board's imposition of personal property tax on vehicles sold by Thomas Dodge to an out-of-state affiliate just prior to March 1, 1987, and second, the imposition of the personal property tax on property Thomas Dodge claims is real property.
I.
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