Rho Co. v. Department of Revenue

Rho Company, Inc. (Rho), appeals the Board of Tax Appeals' (Board) denial of its petition for a refund of B & O taxes.

The facts are largely undisputed. Rho is engaged in the contract personnel business which involves matching individuals with technical skill (contract personnel), usually engineers, with clients or buyers, usually manufacturers or engineering firms, who have a need for such skills for a temporary but not permanent period of time.

Rho matches an available job from a client with contract personnel capable of performing that job. Contract personnel are solicited either through…