Adrian Housing Corp. v. Collins

Hill, Chief Justice.

The appeal in this case is from a trial court order granting summary judgment to Marcus E. Collins, Sr., Revenue Commissioner, and against Adrian Housing Corporation, finding Adrian liable for sales taxes on the full sales price of its prefabricated modular homes. Adrian appeals.1

Adrian was incorporated in 1962 and began fabricating modular homes and relocatable classrooms, a business in which it continues today. Since the tax involved here is primarily on the sales of modular homes, we will discuss Adrian’s operation as it relates to the homes.2 When a “sales contract”…