Mississippi Department of Revenue v. Hotel and Restaurant Supply

COLEMAN, Justice,

for the Court:

¶ 1. The Mississippi Department of Revenue (MDOR) audited Hotel and Restaurant Supply (Hotel) and concluded that

Hotel owed hundreds of thousands of dollars in underpaid sales tax. Hotel appealed the assessment to MDOR’s Board of Review, which upheld the assessment but reduced the amount owed. Hotel appealed to the Mississippi Board of Tax Appeals (MBTA), and MBTA abated the assessment in full. MDOR appealed MBTA’s decision to the Hinds County Chancery Court. Both parties filed motions for summary judgment, and the chancery court granted Hotel’s motion. MDOR…