Ex parte State Department of Revenue

I respectfully dissent from denying this petition for certiorari review.. ,

The petitioner, the State of Alabama Department of Revenue (“the Department”), issued a final assessment for sales-tax liability against Omni Studio, LLC (“Omni”). Pursuant to Ala. Code 1975, § 40-2A-7(b)(5)b„ Omni appealed the Department’s final assessment to the Jefferson Circuit Court. That court entered a summary judgment in favor of Omni and set aside the Department’s final assessment, The Department appealed to the Court of Civil Appeals, which affirmed the judgment of the trial court, State Department of Revenue…