89-011

Response January 17, 1990

 

 

January 17, 1990

 

XXXXX

Corporate Accounting

 

Re: Advisory Opinion - Sales Tax Reporting Method

 

Dear XXXXX:

 

This letter is in response to your December 13, 1989 request for an advisory opinion that XXXXX be allowed to self accrue sales or use tax on your purchases. It is the policy of the Tax Commission to refer such requests to its division most qualified to analyze the request to make recommendations for rendering an opinion. Your request was referred to the Auditing Division whose recommendations are as follows:

 

1. There is no provision in the Utah code or rules authorizing a "direct pay permit." Unless a purchase is for "resale" as tangible personal property, he purchaser is required to pay tax to the vendor, providing the vendor is not an unlicensed out of state vendor. See §59-12-104(28) and Rule R865-19-23S.

 

2. We are not aware of a written document or authorization letter allowing Petitioner to self accrue tax.

 

3. Respondent recommends Petitioner's request be denied and that they be directed to pay tax to vendors of consumable purchases in accordance with current statute and rule.

 

Based upon information furnished by the Auditing Division, we are in agreement with them, and advise that you revise your method of purchasing to comply with law.

 

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 judgment and be appealable to the Utah State Supreme Court. A notice of appeal rights is attached.

 

For the Commission,

 

Joe B. Pacheco

Commissioner

 

M E M O R A N D U M

 

DATE: December 19, 1989

 

TO: XXXXX

Auditing

 

FROM: XXXXX

Commission Secretary

 

SUBJECT: Request for Advisory Opinion

 

XXXXX has requested a declaratory judgment/advisory opinion on XXXXX Sales Tax Authorization.

 

Please respond according to the guidelines established by the Commission. Thank you.

 

13 December 1989

 

XXXXX

 

Utah State Tax Commission

Attention: Commissioners

160 East 300 South

Fifth Floor

Salt Lake City, Utah 84134

 

RE: XXXXX Sales Tax Authorization

 

Dear Commissioners:

 

We recently have gone through a reorganization of XXXXX in XXXXX Utah. Under that reorganization we have organized three separate and distinct divisions which have applied for and received a special authorization to accrue sales and use tax on all purchases made by each division. Our Corporate headquarters are located in the city of Ogden and we would like to use the old XXXXX special authorization to self accrue our own sales and use tax on our purchases made by the Corporate headquarters. That Identification Number is XXXXX. This number has, in the past, been utilized for such purchases at all of our Utah operations.

 

We have been unable to locate an official letter of authorization documenting that use. We would appreciate you so authorizing, in writing, that number for our Corporate headquarters to self-accrue our own sales and use tax on all purchases. This authorization will avoid confusion of many common vendors we have with our XXXXX divisions.

 

If you have any questions regarding this matter, please call me at XXXXX. We appreciate your time and consideration.

 

Sincerely,

 

XXXXX, Director

Corporate Accounting