PHILLIPS, Justice.
During the years 1961, 1962 and 1963, appellant purchased duct work, air conditioning and heating equipment from appellee and paid for these items. As there was some question as to whether appellee's sales were subject to the tax imposed by Article 20.02 (Taxation General) V.A.T.S., it did not bill appellant for the sales tax; however, on a determination being made by the State Comptroller that the tax was due and owing, appellee billed appellant...
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