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SAY PEASE IV v. DEPT. OF REVENUE ADMIN.

No. 2011-174.

42 A.3d 755 (2012)

163 N.H. 415

SAY PEASE IV, LLC and another v. NEW HAMPSHIRE DEPARTMENT OF REVENUE ADMINISTRATION.

Supreme Court of New Hampshire.

Opinion Issued: March 23, 2012.

Attorney(s) appearing for the Case

Casassa and Ryan, of Hampton (John J. Ryan on the brief and orally), for the petitioners.

Michael A. Delaney, attorney general (Matthew G. Mavrogeorge, assistant attorney general, on the brief and orally), for the New Hampshire Department of Revenue Administration.

HICKS, J.

The New Hampshire Department of Revenue Administration (DRA) appeals an order of the Superior Court (McHugh, J.) that reversed DRA's decision assessing a real estate transfer tax against the petitioners, Say Pease, LLC (Say Pease) and Say Pease IV, LLC (Say Pease IV). See RSA 78-B:1 (2003). We affirm.

The parties stipulated to the following facts. Two International Group, LLC (TIG) is a real estate holding company. It owns a ground...

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