SCHULTZ, Justice.
This appeal arises from the assessment of a consumer use tax by the Iowa Department of Revenue and Finance (department) upon Carroll Grudle (owner). This assessment was predicated on his ownership of trucks and trailers used exclusively in his interstate trucking business. The owner protested the assessment, claiming that the trucks and tractors were not purchased for use in Iowa. However, the department, in final agency action, upheld the assessment...
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