CLIFFORD, J.
[¶ 1] J & E Air, Inc. appeals from the summary judgment entered in the Superior Court (Kennebec County, Marden, J.) in favor of the State Tax Assessor. J & E contends that the Superior Court erred in its interpretation of 36 M.R.S.A. § 1760(41) (Supp.2000) and in affirming the assessment of a use tax arising out of its purchase of an aircraft subsequently used in interstate commerce.
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