Miles, Inc. v. Indiana Department of State Revenue

FISHER, Judge.

Miles, Inc. 1 (Miles) appeals the final determination of the Indiana Department of State Revenue (Department) imposing use tax on promotional materials and discount coupons.

ISSUES

I. Whether the Department released Miles from liability for the taxes at issue when it mailed to Miles three "Letters of Resolution."

II. Whether use tax applies to promotional materials that Miles temporarily retains in its Indiana warehouses, but later ships to its sales representatives in other states.

Whether Miles' discount coupons are exempt from use tax under either the incorporation exemption in…