Miami Citizens National Bank & Trust Co. v. Lindley

The decision of the Board of Tax Appeals is affirmed.

The issue presented to this court is whether Miami Citizens’ transactions are excepted from the sales tax under the provisions of B. C. 5739.01(B). That statute provides, in pertinent part:

“ ‘Sale’ and ‘selling’ include all transactions by which title or possession, or both, of tangible personal property, is or is to be transferred * * * for a consideration in any manner * * *.* Other than as provided in this section, ‘sale’ and ‘selling’ do not include professional, insurance, or personal service transactions which involve the transfer of…