90-001

Revised Response February 26, 1990

Response February 22, 1990

 

 

February 26, 1990

 

XXXXX

 

Re: Advisory Opinion, Mail Order Sales

 

Dear XXXXX:

 

This letter is in response to your January 5, 1990 request for an advisory opinion regarding your client's possible liability for collection of use tax on mail order shipments into Utah. It is the policy of the Tax Commission to refer such requests to its division most qualified to analyze the request and make recommendations for rendering an opinion. Your request was referred to the Auditing Division whose recommendations are as follows:

 

1. Utah Code Section 59-12-107 (5) (a) (iii) states "Each vendor shall pay or collect and remit the sales and use taxes imposed by this chapter if within this state the vendor directly or by any agent or other representatives: regularly solicits orders whether or not such orders are accepted in this state, unless the activity in this state consists solely of advertising or of solicitation by direct mail: (iv) regularly engages in the delivery or property in this state other than by common carrier or Unites States mail:"....

 

2. A seller who takes orders from Utah customers in any way other than direct mail solicitation is required to become registered and to collect tax on shipments into Utah. An application is attached.

 

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 State Supreme Court. A notice of appeal rights is attached.

 

Sincerely,

 

Joe B. Pacheco

Commissioner

 

February 22, 1990

 

XXXXX

 

Re: Advisory Opinion, Mail Order Sales

 

Dear XXXXX:

 

This letter is in response to your January 5, 1990 request for an advisory opinion regarding your client's possible liability for collection of use tax on mail order shipments into Utah. It is the policy of the Tax Commission to refer such requests to its division most qualified to analyze the request and make recommendations for rendering an opinion. Your request was referred to the Auditing Division whose recommendations are as follows:

 

1. Utah Code Section 59-12-107(5)(a)(iii) states "Each vendor shall pay or collect and remit the sales and use taxes imposed by this chapter if within this state the vendor directly or by any agent or other representatives: regularly solicits orders whether or not such orders are accepted in this state, unless the activity in this state consists solely of advertising or of solicitation by direct mail; (iv) regularly engages in the delivery of property in this state other than by common carrier or United states mail;"....

 

2. A seller who takes orders from Utah customers in any way other than direct mail solicitation is required to become registered and to collect tax on shipments into Utah. An application is attached.

 

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.

 

Sincerely,

 

Joe B. Pacheco

Commissioner

 

MEMORANDUM

 

TO: COMMISSIONER JOE PACHECO

 

FROM: XXXXX, Director

 

DATE: February 16, 1990

 

RE: Declaratory Judgement/Advisory Opinion

 

Attached is our recommendation for an answer to XXXXX's request for the department's position on the requirement for an out of state mail order house to collect tax.


 

MEMORANDUM

 

TO: XXXXX

 

FROM: XXXXX

 

DATE: February 13, 1990

 

SUBJECT: Request for Advisory Opinion

 

XXXXX has requested a declaratory judgment/advisory opinion on sales and use tax collection for mail order business.

 

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


 

January 5, 1990

 

XXXXX

Chairman

State Tax Commissioner

Heber Wells Office Bldg.

160 East 300 South

Salt Lake City, UT 84134

 

Re: Sales and Use Tax Collection For Mail Order Business

 

Dear Mr. XXXXX:

 

We are writing to obtain the Department's current position as to whether our client is required to collect and remit Utah sales and/or use tax.

 

Our client, who is in the mail order business will place ads offering merchandise for sale in publications which have a national circulation. Orders will be taken either by phone or mail at our client's office in XXXXX State. Orders will be filled by shipping goods from inventory in XXXXX State via the U.S. mail or common carrier. Our client will have no employees nor a place of business nor inventory in your state, nor will our client advertise in local media in your state.

 

Under the circumstances, will our client be required to collect sales/and or use tax from customers in Utah?

 

If our client must collect and remit sales and use tax please notify us as to why they are required to do so and send us the forms necessary to comply with the law along with any other information on the sales and use tax that would be helpful to our client.

 

Your prompt response is much appreciated.

 

Very truly yours,

 

XXXXX