PETITION FOR REVIEW OF A DECISION OF THE ADMINISTRATIVE HEARING COMMISSION
PRICE, Chief Judge.
I.
This case requires us to revisit whether athletic and fitness centers are subject to sales tax on their membership fees. We abandon the "primary purpose test" set out in Columbia Athletic Club that attempted to focus upon the "dual nature" of exercise and return to the "de minimis" test previously set out in Spudich v. Director of...
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