Laws, Regulations & Annotations

Business Taxes Law Guide – Revision 2014
 

Sales and Use Tax Annotations


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S

515.0000 SERVICE ENTERPRISES GENERALLY—Regulation 1501

Annotation 515.0028

(a) IN GENERAL—SERVICE DISTINGUISHED FROM SALE

515.0028 Satellite and Radar Images. Company A obtained satellite images from the U.S. government in a digitized format on magnetic tape. A reproduced visual images of the earth's surface from the tape. A then enhanced certain portions of the image to produce a more useful image of the area. A sold enhanced images to C.

Company B produced a radar mosaic of the same area using the results of a radar survey which it had acquired. The mosaic is an enhancement of previously obtained radar images. B sold enhanced images to C.

The image and the mosaic were utilized by a geologist employed by C to discover physical characteristics of the area covered by them.

Both A's and B's sales are retail sales of tangible personal property. The true object of each contract was the visual representation, not the engineering data produced by the vendor. Both transactions are subject to tax. 9/18/90.