WILDER, J.
In this tax dispute, respondent Department of Treasury appeals as of right from the opinion and judgment of the Michigan Tax Tribunal in favor of petitioner Michigan Milk Producers Association canceling an assessment and ordering a refund of use taxes paid by petitioner pursuant to the Use Tax Act (UTA), M.C.L. § 205.91 et seq.; MSA 7.555(1) et seq. We affirm.
I. Facts and Procedural Background
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