During August 1991, Laurel Transportation, Inc. ("Laurel") purchased a 1987 Cessna Citation III ("Citation III") for $5,300,000 by trading in a Beechcraft King Air and a Cessna Citation II with a combined value of $3,800,000, and by making a cash payment of $1,500,000. The Citation III was purchased out of state and brought into Ohio; however, Laurel paid no use tax, claiming in its unit certificate of exemption that it purchased the...
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