OPINION
DROWOTA, Justice.
We granted the applications of both Colemill Enterprises, Inc. and the Department of Revenue in this action in which Colemill Enterprises, Inc., pursuant to Tenn. Code Ann. § 67-1-1801, challenges an assessment against it of state and local sales taxes. The assessment was based on transactions whereby Colemill Enterprises, Inc. substantially modified airplanes for out-of-state customers.
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