HOWE, Associate Chief Justice:
SEMECO Industries, Inc., seeks review of the denial of its application for a certificate of sales tax exemption which it sought from the Utah State Tax Commission. In its application, SEMECO asserted that it was both a religious institution and a charitable institution, exempt from sales tax under Utah Code Ann. § 59-12-104(8) (Supp.1991).
SEMECO is a Utah nonprofit corporation. Its name is an acronym for Seventh-day
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