HALL, Chief Justice:
Arco Electric ("Arco") appeals from a final order of the Utah State Tax Commission (the "Commission"). The Commission held that it was proper to assess Arco a use tax under Utah Code Ann. § 59-12-103.
The facts of this case and the issues presented do not differ in any material respect from those addressed in Thorup Brothers Construction, Inc. v. Auditing Division of the Utah State Tax Commission,
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