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CITY OF ALEXANDRIA v. MORRISON-WILLIAMS ASSOC.

Record No. 791395.

288 S.E.2d 482 (1982)

CITY OF ALEXANDRIA v. MORRISON-WILLIAMS ASSOCIATES, INC.

Supreme Court of Virginia.

March 12, 1982.

Attorney(s) appearing for the Case

Nolan B. Dawkins, Asst. City Atty., for appellant.

William R. Chambers, McLean (Watt, Tieder, Killian, Toole & Hoffar, McLean, on brief), for appellee.

Before CARRICO, C. J., COCHRAN, POFF, COMPTON, THOMPSON and STEPHENSON, JJ., and HARRISON, Retired Justice.

THOMPSON, Justice.

In this appeal we decide whether Morrison-Williams Associates, Inc. (Taxpayer), an advertising agency, is subject to the gross receipts tax imposed by the City of Alexandria (City)* on total payments received. The trial court found in favor of Taxpayer, and for reasons hereinafter set forth, we reverse.

The evidence, largely stipulated, revealed the following modus operandi for Taxpayer: Client contracts...

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