96-0551

Sales

Signed 1/30/97

BEFORE THE UTAH STATE TAX COMMISSION

____________________________________

COMPANY A

:

:

Petitioner, : ORDER

:

v. :

:

AUDITING DIVISION OF THE : Appeal No. 96-0551

UTAH STATE TAX COMMISSION, :

: Serial No. #####

:

Respondent. : Tax Type: Sales

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STATEMENT OF CASE

This matter came before the Utah State Tax Commission for an Initial Hearing pursuant to the provisions of Utah Code Annotated §59-1-502.5, on December 12, 1996. Alice Shearer, Commissioner, heard the matter for and on behalf of the Commission. Present and representing Petitioner were PETITIONERS REP., Controller, and PETITIONERS REP., a tax representative. Present and representing Respondent were XXXXX, Assistant Attorney General, together with XXXXX, Senior Auditor, and XXXXX, Deputy Director of the Auditing Division.

This appeal was filed March 21, 1996, in response to an amended Utah Sales and Use Tax Audit Summary issued February 22, 1996, covering the audit period April 1, 1992 through March 31, 1995. Both parties filed prehearing memoranda. Six issues remain unsolved.

1. The Auditing Division charged Petitioner use tax on labor charges to repair a large, four-color press. The Auditing Division claims the press is tangible personal property and under Utah Code Annotated §59-12-103(1)(i) charges for repairs are subject to tax.

Petitioner relies upon Tax Bulletin 8-89 which advises that machinery attached to real property for “proper operation” shall be treated as real property for the purpose of computing tax on repairs.

The Auditing Division stated they audited the accrual of use tax, the collection of sales tax and the remittance of all sales and use tax in this audit. Petitioner pointed out that the repairs to the press were handled by a local company that did not charge sales tax.

The Auditing Division agreed that under their interpretation, the repairman should have charged the tax or received an exemption certificate. The Auditing Division will check with them to see why they are not billing and collecting sales tax.

The Auditing Division will amend this audit to remove this assessment of use tax.

2. Petitioner submitted the copy of a check dated April 25, 1994, that was payment for custom software. Respondent had assumed the purchase was for non-custom software and charged “use” tax on the purchase. Respondent will amend the audit to remove this item from purchases subject to use tax.

3. Pre-press material was not taxed appropriately. Petitioner removed the statement that had been preprinted on its invoices that stated that title to pre-press materials passed to the customer unless specifically exempted. Because of this change on their invoices, Respondent applied tax to the whole transaction. Petitioner thought the requirement about the preprinted notice on the invoice was “picky” as they had been collecting accurately. Respondent noted that this issue had been part of a previous audit so the company knew what they should do.

The Commission affirms the position of Respondent on this issue.

4. Petitioner purchased a four-color press to replace and upgrade the printing process. The old press was traded in for this new one. The new one is more productive and does better and faster printing. Petitioner is relying on the Newspaper Agency decision from the Court of Appeals to justify taking the manufacturer’s exemption from sales tax on this equipment. Respondent states the purchase was replacement equipment and as such is not entitled to the exemption, as per the recent Supreme Court decision in Eaton-Kenway vs. Auditing Division, Utah State Tax Commission, 906P.2d882 (Utah 1995). The Commission agrees that Eaton-Kenway controls the most current case from the highest Utah court. Petitioner must pay the sales tax on the purchase of the press.

5. In the audit, Respondent charged Petitioner is liable for sales tax on a sale Petitioner claims was a sale for resale. Respondent does not dispute that it may be a sale for resale but assessed the tax because Petitioner has no exemption certificate or other evidence that the sale is exempt. Substitute evidence is acceptable (as the Commission has said in the case of government entities), however, there is no evidence at all in this case and that is unacceptable. Petitioner is liable for the tax.

6. Respondent has explained to Petitioner that the 10% penalty related to the exemption taken on the purchase of the press is not imposed for non-payment of the tax or, for late payment but for non-reporting as required on line 10 of the sales tax form. Petitioner now understands and agreed to pay the penalty.

DECISION AND ORDER

The Commission has considered the documents in the file of this case and discussed the arguments presented at the Initial Hearing. The decisions noted on the issues presented will be final unless appealed to Formal Hearing.

This decision does not limit a party’s right to a Formal Hearing. However, this Decision and Order will become final unless any party to this case files a written request within thirty (30) days of the date of this decision to proceed to a Formal Hearing. Such a request shall be mailed to the address listed below and must include the Petitioner’s name, address, and appeal number:

Utah State Tax Commission

Appeals Division

210 North 1950 West

Salt Lake City, UT 84134

Failure to request a Formal Hearing will preclude any further administrative action or appeal rights in this matter.

DATED this 30th day of January, 1997.

BY ORDER OF THE UTAH STATE TAX COMMISSION.

W. Val Oveson Richard B. McKeown

Chairman Commissioner

Joe B. Pacheco Alice Shearer

Commissioner Commissioner

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