Pioneer Markets, Inc. v. Commissioner of Revenue

BIEGELMEIER, Judge.

*25The question involved in the appeal is whether the membership fee charged by appellant stores is subject to tax imposed by SDC 57, the South Dakota Retail Occupational Sales Tax. Appellant corporations are engaged in sales of groceries and related merchandise at retail and hold permits or licenses to engage in business as retailers, SDC 57.3301, as amended by Ch. 329, S.L.1967.1 Their method of doing business is to charge a $2.00 membership fee to persons desiring to purchase merchandise at their stores. They receive membership cards good for a month during which time they…