OPINION
HOWARD, Chief Judge.
This is an appeal from a granting of a summary judgment in favor of appellee. The facts are not in dispute and only a question of law is involved.
Section 19-91 of the Tucson City Code imposes a business privilege tax on certain business activities. The code sets forth three conditions which must be met before the activity is not taxable. (Sections 19-91(1), (2) and (3).) The transfer of title and possession of the item...
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