Nutrition Headquarters, Inc. v. Department of Revenue

We are here called upon to decide whether the act of attaching mailing labels to, sorting, and mailing catalogs which are brought into Illinois for the sole-purpose of labeling and mailing the material for delivery throughout the United States is exempt from taxation under the Service Use Tax Act (the Act) (Ill. Rev. Stat. 1979, ch. 120, par. 439.31 et seq.).

Nutrition Headquarters, Inc., the plaintiff taxpayer, is a Delaware corporation authorized to operate a mail-order vitamin and health food business in Illinois. The plaintiff’s catalogs are printed and stamped in preparation for mailing…