RIMM, J.T.C.
This is a state tax matter arising under the Sales and Use Tax Act, N.J.S.A. 54:32B-1 to 54:32B-29, in which plaintiff seeks an exemption for the price paid for his boat, Venture III, under N.J.S.A. 54:32B-8.12 (§ 8.12). The statute which is the subject of this litigation reads as follows in pertinent part:
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