STEWART, Justice:
BJ-Titan Services Company ("BJ-Titan") seeks review of the Utah State Tax Commission's ruling which imposed sales and use taxes on BJ-Titan's oil and gas well stimulation services and on a transfer of motor vehicles from BJ-Hughes Holding Company ("BJ-Hughes") to BJ-Titan. We reverse in part and remand.
FACTS
The basic facts are undisputed. The appeal before the Commission involved two consolidated cases: Hughes Tool Co. v. Auditing...
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