BENTON, Chief Justice.
In 1990, 1991 and 1992, International Business Machines Corporation sold mainframe computers, document scanners, direct storage devices, tape drives and printers to DST Systems, Inc., for $21,456,387.56. IBM remitted sales tax on these items to the Director of Revenue, but later claimed a refund of $1,388,870.38 based on the exemption in section 144.030.2(5) RSMo Supp.1990.
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