Matrix Funding Corp. v. Auditing Division of the Utah State Tax Commission

ON CERTIORARI TO THE UTAH COURT OF APPEALS

STEWART, Associate Chief Justice:

Matrix Funding Corporation petitions for review of a Utah Court of Appeals ruling affirming an advisory opinion of the Utah State Tax Commission. That opinion held that the Utah sales tax would apply to a proposed sale-leaseback transaction. We hold that passage of Utah Code Ann. § 59-12-102(13)(e) (Supp.1995) has rendered the question moot.

In May 1991, Matrix requested an advisory opinion from the Utah State Tax Commission as to whether the sales tax applied to a hypothetical sale-leaseback transaction between Matrix…