SOL GOTHARD, Judge.
The plaintiff, Shell Oil Co. ("Shell"), appeals the judgment of the trial court denying its motion for summary judgment and granting the motion for summary judgment filed by defendants, St. Charles Parish School Board and R.J. Lorio, Director of Tax Collection, St. Charles Parish School Board, Sales & Use Tax Department ("St.Charles"). For the following reasons, we affirm in part and reverse in part the decision of the trial court.
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