SILVER, J.
[¶ 1] The State Tax Assessor appeals from a judgment of the Superior Court (Kennebec County, Studstrup, J.) vacating the tax assessment against Stewart Title Guaranty Company for the years 1999, 2000, 2001, and 2002, and granting and denying, in part, both parties' motions for summary judgment. The court ultimately remanded the matter to the State Tax Assessor for a determination of the appropriate tax pursuant to 36 M.R.S. § 2519 (2005...
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