City of Phoenix v. Paper Distributors of Arizona, Inc.

OPINION

SCHAFER, Judge.

The issue presented in this case is whether a paper distributor’s sales of paper products to restaurants are sales for resale which fall outside the scope of the “sales” tax provision of the Phoenix City Code.

FACTS

Paper Distributors of Arizona (“Taxpayer”) is a wholesale distributor of paper and plastic products, such as bulk paper, paper towels, and disposable food service items including paper bags, sandwich wrappings, paper cups, and plastic silverware (“paper products”). These products are used by Paper Distributors’s restaurant customers to package food products for…