Gulf Coast Rental Tool Service, Inc. v. Collector of Revenue

TATE, Judge.

The Collector of Revenue appeals from judgment ordering the refund of certain State sales taxes paid under .protest which plaintiff sued to recover as provided by LSA-R.S. 47:1576.

Broadly stated, the issue herein is whether “leases for re-leasing” are exempt from the two per cent lease and rental tax feature of the Louisiana Sales Tax, LSA-R.S. 47:301 et seq., see Section 302, subd. B; as, specifically, are “sales for re-sale” from the sales tax provisions thereof, LSA-R.S. 47:302, subd. A, 301(10).

The plaintiff taxpayer further contends that a legal relationship characterized by…