DURHAM, Chief Justice:
INTRODUCTION
¶ 1 Plaintiff Dick Simon Trucking, Inc. (Dick Simon) purchased satellite tracking units and attached them to new trucks that it uses in its trucking business. Following an audit, the Utah State Tax Commission (the Commission) concluded that the purchases were purchases of tangible personal property, and assessed sales tax accordingly. Dick Simon petitioned the Commission for reconsideration, arguing that the satellite...
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