ZIMMERMAN, Justice:
¶ 1 Airport Hilton Ventures, Ltd. ("Hilton") seeks review of a Tax Commission ("Commission") order assessing sales and use taxes (hereinafter collectively referred to as "sales taxes") and transient room taxes on charges Hilton made for guaranteed hotel accommodations for the period of January 1992 through March 1995. In finding Hilton liable, the Commission relied on Utah Administrative Code R865-19S-79, a rule the Commission promulgated...
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