Corporate Staffing Resources, Inc. v. Zaino

This appeal presents the question whether a company that uses technicians supplied by a temporary employment service to satisfy maintenance and repair contracts for products sold to its customers meets the R.C. 5739.01(E)(1) resale exception to the state use tax. Because we conclude that the company does not resell the benefit obtained from the temporary employment service in the same form in which it was received, we hold the resale exception inapplicable.

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Sarcom, Inc. is a computer hardware provider that, among other products, offers its customers a “full insurance plan” service agreement.…