SINGLEY, J., delivered the opinion of the Court.
In this appeal from the Maryland Tax Court, Greyhound Computer Corporation (Greyhound) challenges an order of the tax court which affirmed an assessment of $1,501,350.00 imposed for the tax year 1970-71 by the State Department of Assessments and Taxation (the Department) on four computer systems owned by Greyhound and leased to Bendix Corporation at Towson, Maryland.
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