PER CURIAM.
Plaintiff John F. Heuer contests the imposition of a use tax by New Jersey upon the use in this state of his fifty-foot boat, which he purchased in Maryland at a public sale ordered by the United States District Court for the District of Maryland in 1987.
The Tax Court of New Jersey heard the matter on cross-motions for summary judgment with certain stipulated facts. There is no question that Heuer did not pay any sales or use tax to either Maryland...
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