Destroyed property

From the 2024 DOR Tax Exemption Study

Det. No. 13-0144, 33 WTD 14 (February 3, 2014) 15 comprised of $. . . in small business credit, $. . . in retail sales tax, $. . . in retailing business and occupation (B&O) tax, $. . . in wholesaling B&O tax, $. . . in interest, and a 5% assessment penalty of $. . .. Taxpayer raised three issues on appeal. The first two were resolved by Audit with a post assessment adjustment (PAA).2 The third issue, however, was not resolved. Taxpayer asserted that the assessment was incorrect because sales of currency were included in the measure of retail sales tax and are exempt as legal tender up to the face value in US dollars with the remainder subject to service and other activities B&O tax. The sales invoices that were sampled showed sales of currency, comprised of $1,000 bills, $500 bills, and silver certificates,3 which may be legal tender, but are not generally recognized as a medium of exchange for goods and services.4 Audit found that these were sales of tangible personal property and made no adjustment. In support of its assertion, Taxpayer provided a copy of a letter from the Department’s Taxpayer Information and Education Section (TI&E) dated March 7, 1997. The letter has a blank