Moon Shadow, Inc. v. Director of Revenue

Moon Shadow, Inc., operates as a recreational concessionaire of the United States Park Service on the banks of the Current River, near Van Burén, Missouri. Moon Shadow bought over 1,000 truck and tractor inner tubes, paying sales tax at the time of purchase. Moon Shadow did not resell the tubes, but rented them to customers for floating the river. Moon Shadow modified some 400 of the inner tubes by adding an adjustable mesh seat and a metal ring for attaching a cooler. The tubes are propelled by the river’s current, and occasionally by paddle. Moon Shadow transports the customer and the tube…