Accountant's Computer Services, Inc. v. Kosydar

The essential issue common to each of these three eases is the applicability of the exception from taxation provided by R. C. 5739.01(B) for items of tangible personal property which are transferred, as an inconsequential element for which no separate charge is made, in conjunction with a transaction which also involves some significant degree of contracted-for service. Resolution of this issue necessitates an examination of the taxing scheme provided by statute in Ohio.

The Board of Tax Appeals, in its decisions, placed controlling weight upon the combined impact of two clauseg found in R, C.…