Intellidata Inc. v. State Board of Equalization

Opinion

MILLER, J.

In this action we consider whether transactions between keypunch service companies and their customers are properly taxable as sales of tangible personal property within the meaning of the California Sales and Use Tax Law. (Rev. & Tax. Code, § 6001 et seq.)

The underlying facts in this case are generally undisputed. Intellidata Incorporated (hereinafter plaintiff) is a computer service bureau. Among other operations it provides keypunching services for corporations that own their own computer. The keypunching service may be described as follows:

Plaintiffs customer delivered…