OPINION
PER CURIAM:
The facts in this case are brief and undisputed. Indeed, both parties stipulated that only issues of law exist for this court to decide.
On November 10, 1987, respondent State of Nevada, Department of Taxation ("Department"), granted appellant Key Airlines, Inc. ("Key") a sales and use tax exemption on its aircraft pursuant to NRS 372.317. NRS 372.317 states:
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