OPINION
DIANE M. HENSON, Justice.
In this suit for a refund of use taxes paid on out-of-state purchases of certain surgical instruments, appellant Zimmer US, Inc. appeals from the trial court's order denying its motion for summary judgment and granting summary judgment in favor of appellees, Susan Combs, Comptroller of Public Accounts, and Greg Abbott, Attorney General of the State of Texas (collectively, "the Comptroller"). See Tex. Tax Code...
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