Issue: (1) Whether the Taxpayer maintained shipping documentation adequate to exempt retail sales of boats and other tangible personal property made and delivered to customers out-of-state.

(2) Whether the Taxpayer’s sales of used boats and motors taken in trade are subject to North Carolina sales tax.

(3) Whether the Department is barred from assessing the Taxpayer the additional tax as a result of erroneous verbal advice rendered by an employee of the Department of Revenue.