FISHER, Judge.
Petitioner, State Line Elevator, Inc., has filed an original tax appeal concerning the Respondent's, State Board of Tax Commissioners, final determination that State Line is liable for additional business personal property tax on grain stored in its elevators on March 1, 1986. The State Board has filed a motion for partial summary judgment, in which it asks this court to decide two issues as a matter of law. The issues involved are:
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