Cooperative Agronomy Services v. South Dakota Department of Revenue

ZINTER, Justice.

[¶ 1.] The South Dakota Department of Revenue (Department) assessed sales tax on a fertilizer storage service Cooperative Agronomy Services (CAS) provided other cooperatives. The circuit court reversed the assessment on appeal, and we reverse.

FACTS

[¶2.] CAS is a cooperative association located in Groton, South Dakota. CAS was incorporated by approximately twelve North and South Dakota locally owned cooperatives. According to the articles of incorporation, CAS’ purpose was to reduce “the member cooperatives’ costs through joint action in purchasing and distributing supplies…