89-002

Response December 8, 1989

 

 

December 8, 1989

 

XXXXX

 

Re: Sales Tax - Manufacturers Exemption

 

Dear XXXXX:

 

This letter is in response to your May 4, 1989 request for a Tax Commission ruling on whether a laser typesetter and a display adbuilder workstation qualify for sales tax exemption under Sales Tax Rule R865-19-85S and §59-12-104(16).

 

Although your inquiry was framed as a request for a declaratory judgement, Tax Commission policy is to initially treat all such inquiries as requests for advisory opinions. As such, it was referred to the Tax Commission's Auditing Division for their analysis and recommendation. The division's recommendation is as follows:

 

1. Your purchase of the infrared diode laser typesetter is tax exempt, based upon it being an additional typesetting machine and will not replace an existing one.

 

2. Your purchase of the display adbuilder workstation is also tax exempt since it does not replace other equipment and allows you to perform a new function by automation.

 

Based on the facts presented in your letters, we are in agreement with the Auditing Division's recommendations. Obviously, if there are deviations from these facts, this opinion may be negated.

 

If you do not agree with this determination, you may appeal to the Tax Commission for a formal hearing. The results of that hearing would constitute a declaratory judgement and be appealable to the Utah Supreme Court. A notice of appeal rights is attached.

 

For The Commission,

 

Joe B. Pacheco

Commissioner

 

TO: Utah State Tax Commission

 

DATE: May 4, 1989

 

SUBJECT: S85 Exemption

 

XXXXX is currently installing a XXXXX Display Adbuilder Workstation. This is a computerized ad makeup system. The purchase price of this system is $$$$$. This equipment does not replace any other equipment at XXXXX nor has XXXXX ever owned equipment to perform this function. I believe this equipment is exempt from Utah State Sales Tax under rule A12-02-S85. In order to avoid the possible future assessment of sales tax, penalty, and interest I would like a declaratory judgement to determine whether this piece of equipment qualifies for exemption.

 

Please contact me if you have any questions or need additional information.

 

Cordially,

 

XXXXX

Director of Finance

 

TO: Utah State Tax Commission

 

DATE: May 4, 1989

 

SUBJECT: S85 Exemption

 

XXXXX is currently installing a Linotype L-200P infrared diode laser typesetter. The purchase price of the typesetter and associated type fonts is $$$$$. XXXXX currently has a typesetter which will continue in full-time use into the foreseeable future. This equipment is additional equipment to help reduce the backlog of work in the ad make-up and typesetting departments. I believe this equipment is exempt from sales tax under rule A12-02-S85. In order to avoid the possible future of assessment of sales tax, penalty, and interest I would like a declaratory judgement to determine whether this piece of equipment qualifies for exemption.

 

Please contact me if you have any questions or need additional information.

 

Cordially,

 

XXXXX

Director of Finance