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BIG AL'S TOWING v. DEPT. OF REVENUE

S-22-0074.

520 P.3d 97 (2022)

2022 WY 145

BIG AL'S TOWING AND RECOVERY, Appellant (Respondent), v. State of Wyoming, DEPARTMENT OF REVENUE, Appellee (Petitioner).

Supreme Court of Wyoming.

November 15, 2022.

Attorney(s) appearing for the Case

Representing Appellant: James O. Bardwell , Christopher M. Brennan , and Gay Woodhouse , Woodhouse Roden Ames & Brennan, LLC, Cheyenne, Wyoming. Argument by Mr. Brennan.

Representing Appellee: Bridget L. Hill , Attorney General; Brandi Lee Monger , Deputy Attorney General; Karl D. Anderson , Senior Assistant Attorney General; Douglas Brodbeck , Assistant Attorney General. Argument by Mr. Brodbeck.

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

[¶1] Wyo. Stat. Ann. § 39-15-103(a)(i)(J) (LexisNexis 2021) levies an excise tax on "[t]he sales price paid for services performed for the repair, alteration or improvement of tangible personal property[.]" This appeal concerns whether three roadside services offered by Big Al's Towing and Recovery (Big Al's)—...

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