Sharper Image Corp. v. Miller

The plaintiff appeals from the judgment rendered by the trial court confirming the imposition of a use tax by the defendant commissioner of revenue services (commissioner) on its catalogs mailed to Connecticut residents. The issue is whether the trial court correctly determined that the mailing of catalogs directly to Connecticut residents advertising the plaintiffs merchandise constituted a taxable use within the meaning of General Statutes §§ 12-411 and 12-407 (5), in that Sharper Image “owned” the catalogs in Connecticut, and made a taxable “use” of them under applicable *311statutes,…