WILKINS, J.
The plaintiff purchased a boat from a Connecticut boat dealer which was not a vendor registered under G.L.c. 62C, § 67. As partial payment of the purchase price, the plaintiff traded in a boat. The plaintiff paid a use tax to the Commonwealth based on the difference between the purchase price of the new boat and the trade-in value of the old boat. The Commissioner of Revenue demanded payment of a use tax based on the full purchase price of the new...
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