Indiana Department of State Revenue v. William A. Pope Co.

The Gross Income Tax Division of the Indiana Department of State Revenue appeals from a trial court decision that the entire Indiana income ($8,108,484.00) received by the William A. Pope Company in 1970, 1971, and 1972, should be *316classified as income received by a retail merchant from selling at retail and thereby subject to gross income tax liability at the rate of one half of one percent rather than the mixed rate of two percent for installation income and one half of one percent for sales income as assessed by the department.

We reverse.

Pope, an Illinois Corporation doing business as a…