Thomas Nelson, Inc. v. Olsen

OPINION

FONES, Justice.

The issue before this Court is whether advertising design models received pursuant to contracts for the development of advertising ideas are tangible personal property within the purview of Tennessee’s Use Tax. We hold that these models were a crucial element of the contracts to conceive an advertising concept, rendering the costs of these transactions subject to the Use Tax.

Taxpayer is a Tennessee corporation, with its principal offices in Nashville, engaged in the publication of Bibles and other books and materials. Taxpayer regularly commissioned an Illinois…