BENTON, Judge.
The Administrative Hearing Commission upheld the Director's assessment of sales and use tax on Blevins Asphalt Construction Company for: (1) paving materials that it purchased and then used to meet its installation contracts; (2) sales to out-of-state municipalities; and (3) paving equipment. This Court has jurisdiction of Blevins' appeal. Mo. Const. art V, § 3; § 621.189.
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