Woodward, Hobson & Fulton, L.L.P. v. Revenue Cabinet

OPINION

BARBER, Judge.

We are asked to decide whether a law firm is required to pay use tax upon charges for photocopies of medical and hospital records acquired from out-of-state providers in connection with litigation. For the reasons set forth below, we conclude that the transactions at issue are not subject to the use tax and reverse.

The Appellant, Woodward, Hopson & Fulton, L.L.P. (‘Woodward”), is a Kentucky law firm. The Revenue Cabinet audited Woodward for the period of January 1, 1984 through March 31, 1993, and determined that $2,592.79 was owed in use tax on Woodward’s acquisition of…