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ARCHER DANIELS MIDLAND CO. v. PARISH SCHOOL BD.

No. 2001-C-0511.

802 So.2d 1270 (2001)

ARCHER DANIELS MIDLAND COMPANY, et al. v. The PARISH SCHOOL BOARD OF THE PARISH OF ST. CHARLES, Individually and as Collecting Agent for the Parish Council of St. Charles, et al. Tulane Fleeting, Inc. v. The Parish School Board of the Parish of St. Charles, Individually and as Collecting Agent for the Parish Council of St. Charles, et al.

Supreme Court of Louisiana.

Rehearing Denied March 18, 2002.

Attorney(s) appearing for the Case

Roy M. Lilly, Jr., Minden, Andrew A. Lemmon, New Orleans, for Applicant.

William M. Backstrom, Jr., Laura L. Blackston, Jones, Walker, Waechter, Poitevent, Carrere & Denegre, New Orleans, for Respondent.

Larry Dewayne Dyess, Belle Chasse, for St. John Parish School Bd., Ascension Parish Tax Authority, West Baton Rouge Parish Dept. of Revenue (Amicus Curiae).

Johnette L. Martin, Houma, for Plaquemines Parish Government, Palquemines Parish Council (Amicus Curiae).

John D. Schoonenberg, Houma, for Terrebonne Parish Sales Tax & Use Dept. (Amicus Curiae).

Geneva Landrum, Baton Rouge, for Cynthia Bridges, Secretary of Dept. of Revenue (Amicus Curiae).

John L. Lanier, Thibodeaux, for Lafourche Parish School Bd. (Amicus Curiae).

Lea A. Batson, Baton Rouge, for East Baton Rouge Parish Dept. of Revenue (Amicus Curiae).

Alan G. Brackett, New Orleans, Stephen M. Huber, River Ridge, for Greater New Orleans Barge Fleeting Ass'n (Amicus Curiae).

KNOLL, Justice.*

This writ concerns whether a group of taxpayers, which operates tugboats wholly within Louisiana waters, is entitled to a sales tax exemption under a parish ordinance exempting fuel purchases by "owners or operators of ships or vessels operating exclusively in foreign or interstate coastwise commerce." Because taxpayers' tugboats operate wholly within Louisiana waters, we find taxpayers' tugboats are not "operating exclusively...

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