DANA, J.
[¶ 1] Fairchild Semiconductor Corporation appeals from a judgment entered in the Superior Court (Kennebec County, Marden, J.) affirming a decision of the State Tax Assessor assessing additional taxes against Fairchild for the 1988 tax year. Fairchild argues that the Assessor misapplied 36 M.R.S.A. § 5102(8)
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