OPINION BY Judge McGINLEY.
Randal V. Kline and Carol L. Kline (collectively, Petitioners) petition for review from an order of the Board of Finance and Revenue (Board) that affirmed the imposition of a realty transfer tax on each of the twenty-seven conveyances from Petitioners to Randcar, LLP.
The Petitioners, husband and wife, stipulated to the following:
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