SCHOTT, Chief Judge.
The issue in this case is whether the state may collect tax on the sale of supplies to the operators of foreign ships bound for foreign ports where the supplies are for use and consumption during the voyage in the absence of a specific statutory exemption from the tax. We hold that it may not.
This is an action by the Secretary of the Department of Revenue and Taxation to collect sales taxes for the period July 1, 1986 through June 30...
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