Qualcomm, Inc. v. Department of Revenue

¶1 Qualcomm Inc. sells the “OmniTRACS” system to trucking companies. The system includes hardware, software, and a service that collects, manipulates, and transmits data from the trucks to the companies’ dispatch centers. Under our tax system, the legislature imposes different business and occupation (B&O) tax rates depending on the nature of the business. Thus the “retailing B&O” tax rate is lower than the “service B&O” tax rate. Similarly, retail sales tax applies to some transactions but not others. “Network telephone services,” as defined by statute, are subject to both retailing B&O tax…