93-019

Response July 9, 1993

 

 

Request

April 30, 1993

 

Utah State Tax Commission

160 East 300 South

Salt Lake City, Utah 84134

 

Gentlemen

 

SUBJECT: Request for Declaratory Judgement

 

XXXXX, located at above address, has recently completed a sales tax audit supervised by your field auditor, XXXXX. During the course of this audit I was informed by XXXXX that it was not necessary to collect sales tax on the use of the public scales located at the Truck Stop. I have passed this information on to the manager of the Truck Stop, but feel that in order to best protect our interests it will be imperative that we have this information in writing for future reference.

 

Thank you for your cooperation in this mater.

 

Sincerely

 

XXXXX

 

July 9, 1993

 

XXXXX

 

Re: Declaratory Judgment - Sales Tax on Charges for Use of Weigh Scales

 

Dear XXXXX:

 

This letter is in response to your recent request for the Tax Commission to issue a declaratory judgment that your charges for use of public weigh scales are not subject to tax under the Utah Sales and Use Tax Act.

 

Although your inquiry was framed as a request for a declaratory judgment, 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 recommendations. The division's recommendations are as follows:

 

1. It is assumed that the scales of concern are permanently affixed at a specific location and are not portable.

 

2. While charges for use of such public weigh scales are not specifically exempt under the language of the statutes, such charges are exempt by exclusion from the innumeration of transactions subject to tax under the act. Consequently, you should not collect sales tax on charges for use of weigh scales.

 

3. The rental of portable scales would, however, be subject to the tax.

 

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

 

If you do not agree with the 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 Supreme Court. A Notice of Appeal Rights and a copy of the Utah Taxpayer Bill of Rights are attached.

 

For the Commission,

 

Joe B. Pacheco Commissioner