Commonwealth v. Research Analysis Corp.

Research Analysis Corporation (RAC) filed in the court below two petitions for correction of allegedly erroneous sales and use tax assessments made by the Department of Taxation against RAC’s leased 1 computer for the years 1966 through 1970. The cases were consolidated for trial and the trial court, sitting without a jury, held that under the provisions of Code § 58-441.6(q) the computer was exempt from the tax and the assessments were erroneous. We granted the Commonwealth a writ of error to the judgment.

Code § 58-441.6 (q) exempts the following from sales and use taxation:

“Tangible…