VALGARDSON HOUSING SYSTEMS v. TAX COM'N

No. 920644-CA.

849 P.2d 618 (1993)

VALGARDSON HOUSING SYSTEMS, INC., Petitioner, v. STATE TAX COMMISSION, Respondent.

Court of Appeals of Utah.

Rehearing Denied April 6, 1993.


Attorney(s) appearing for the Case

W. Andrew McCullough, Orem, for petitioner.

Jan Graham and Clark L. Snelson, Salt Lake City, for respondent.

Before GARFF, GREENWOOD and ORME, JJ.


OPINION

GREENWOOD, Judge:

Petitioner appeals a decision from a formal hearing of the Utah State Tax Commission assessing it for delinquent taxes on certain sales of modular housing units to dealers. The Tax Commission determined that when petitioner transferred these modular units prior to permanent attachment to real property, it sold tangible personal property subject to sales tax. We affirm.

BACKGROUND

Petitioner, Valgardson Housing...

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