Bay Mechanical & Electrical Corp. v. Testa

{¶ 1} In this case, Bay Mechanical & Electrical Corporation, a specialty mechanical contractor, challenges a sales-tax assessment issued by the tax commissioner with respect to Bay’s purchase of allegedly taxable “employment services.” During the audit period, which extends from January 1, 2003, through December 31, 2005, Bay purchased the services from two entities. Bay treated the personnel supplied by Tradesmen International, Inc. and Construction Labor Contractors (“CLC”) as “permanent-assignment” employees and therefore re*424garded the attendant employment services as exempt pursuant to…