Comptroller Hearing No. 101.806 involved the exemption provided to flight instructors in Tax Code § 151.328(a)(2). This statute permits persons engaged in flight instruction to purchase aircraft sales-tax-free. One condition of the exemption is that the instructor must have a sales tax permit. In the hearing decision, the ALJ agreed that flight instruction is not a taxable service, and on its face, there is seemingly no reason for a flight instructor to have a sales tax permit. But, since the requirement to have the permit is part of the exemption statute, the Comptroller cannot ignore it. The taxpayer in this case was denied the exemption for flight school aircraft because it did not have a sales tax permit when it brought the aircraft into Texas.