Thorne & Wilson, Inc. v. Utah State Tax Commission

STEWART, Justice:

The appellant is a broker/dealer company in the investment business. It brought this action to obtain a declaration that it is not subject to sales taxes for the sale of precious metals, bars, and medallions; United States coins; and foreign coins, such as South African Krugerrands. The district court held the sale of those items subject to the state sales tax. We affirm.

I

The question on this appeal is whether rare United States coins, foreign coins, and precious metals are money or “tangible property” as that term is used in U.C.A., 1953, § 59-15-4(a), which imposes “[a] tax…