McGINLEY, Judge.
Hempt Bros., Inc. and Hempt Farms (Petitioners) petition for review of orders of the Board of Finance and Revenue (Board) sustaining decisions of the Board of Appeals of the Department of Revenue (Department) which sustained a use tax assessed against Petitioners on their purchase of shares in four syndications of standard bred stallions. The issue presented for our review is whether the Petitioners' purchase of shares in the syndications, which entitled...
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