OPINION
GREENWOOD, Judge:
Petitioner appeals a decision from a formal hearing of the Utah State Tax Commission assessing it for delinquent taxes on certain sales of modular housing units to dealers. The Tax Commission determined that when petitioner transferred these modular units prior to permanent attachment to real property, it sold tangible personal property subject to sales tax. We affirm.
BACKGROUND
Petitioner, Valgardson Housing...
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