In this case we determine whether a taxpayer owes sales and use taxes on its purchases of boxes, styrofoam peanuts, strapping, tape, and labels (the "packing material") with which it packages and protects its merchandise for delivery to the end purchaser. The Administrative Hearing Commission affirmed the decision of the Director of the Department of Revenue that appellant owed the sales and use taxes it previously paid under protest. Appellant filed a petition for review...
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