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DELCON PARTNERS v. WYOMING DEPT. OF REVENUE

S-19-0078.

450 P.3d 682 (2019)

2019 WY 106

DELCON PARTNERS LLC, Appellant (Petitioner), v. WYOMING DEPARTMENT OF REVENUE, Appellee (Respondent).

Supreme Court of Wyoming.

October 21, 2019.

Attorney(s) appearing for the Case

Representing Appellant: Matthew Kim-Miller , Holland & Hart LLP, Jackson, Wyoming. Argument by Mr. Kim-Miller.

Representing Appellee: Bridget Hill , Attorney General; Brandi Monger , Deputy Attorney General; Karl Anderson , Senior Assistant Attorney General; Andrew Kuhlmann , Senior Assistant Attorney General. Argument by Mr. Anderson.

Before DAVIS, C.J., and FOX, KAUTZ, BOOMGAARDEN, and GRAY, JJ.

[¶1] Delcon Partners, LLC (Delcon) purchased 28% of Delcon, Inc.'s1 (Seller's) tangible and intangible assets. The Department of Revenue (Department) determined the transaction was not exempt from sales tax because Delcon did not purchase at least 80% of the total value of Seller's assets, which included...

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