SFA FOLIO COLLECTIONS, INC. v. BANNON

(14023)

217 Conn. 220 (1991)

SFA FOLIO COLLECTIONS, INC. v. TIMOTHY F. BANNON, COMMISSIONER OF REVENUE SERVICES

Supreme Court of Connecticut.

Decision released January 22, 1991.


Attorney(s) appearing for the Case

Richard K. Greenberg, assistant attorney general, with whom were John G. Haines, assistant attorney general, and, on the brief, Clarine Nardi Riddle, attorney general, and Jane D. Comerford, assistant attorney general, for the appellant (defendant).

Maryann B. Gall, with whom were Laura A. Kulwicki and William H. Narwold, for the appellee (plaintiff).

PETERS, C. J., SHEA, COVELLO, HULL and BORDEN, JS.


BORDEN, J.

The issue in this tax appeal is whether the trial court correctly determined that the imposition of Connecticut sales and use taxes on the plaintiff, SFA Folio Collections, Inc. (Folio), a mail order company, was a violation of the due process and commerce clauses of the United States constitution because Folio lacks a sufficient nexus to the state. The defendant, the commissioner of revenue services (commissioner), assessed Folio with sales and use taxes...

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