S.C. TAX COMMISSION v. S.C. TAX BOARD OF REVIEW

23387

305 S.C. 183 (1991)

407 S.E.2d 627

SOUTH CAROLINA TAX COMMISSION, Appellant-Respondent v. SOUTH CAROLINA TAX BOARD OF REVIEW, Collins Music Co., Inc. and Collins Novelty Co., Inc., of whom Collins Music Co., Inc. and Collins Novelty Co., Inc. are, Respondents-Appellants.

Supreme Court of South Carolina.

Decided May 6, 1991.

Rehearing Denied August 15, 1991.


Attorney(s) appearing for the Case

Chief Deputy Atty. Gen. Joe L. Allen, Jr. and Deputy Atty. Gen. Ray N. Stevens, Columbia, for appellant-respondent.

Curtis W. Stodghill and Robert A. Dobson, III, both of Dobson and Dobson, and John W. Kittredge, of Wilkins, Nelson & Kittredge, Greenville, for respondents-appellants.


Heard Feb. 19, 1991.

Decided May 6, 1991.

Rehearing Denied Aug. 15, 1991.

TOAL, Justice:

This appeal arises out of a dispute between appellant South Carolina Tax Commission (Tax Commission) and respondents Collins Music Co., Inc. and Collins Novelty Co., Inc. (Collins) over the valuation of certain property as merchant's equipment pursuant to S.C. Code Ann. § 12-37-970.1 If property is

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