PER CURIAM.
Defendant appeals as of right a judgment for plaintiff in which the Court of Claims ordered that defendant repay plaintiff $1,782,343.82 in use taxes, inclusive of interest, that plaintiff previously paid to defendant under protest. We hold that the use tax under the Use Tax Act (UTA), M.C.L. § 205.91 et seq.; MSA 7.555(1) et seq., does not apply under the circumstances in this case, and therefore we affirm.
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