R & M Enterprises, Inc. v. Director of Revenue

BLACKMAR, Judge.

The appellant is a wholesaler of yard goods. It sends specimens of the patterns in inventory to fabricators in other states which cut them into small samples and bind the samples into books. The completed books are then sent by contract carrier to the appellant’s place of business in Cape Girardeau, where the appellant addresses the individual books and transmits them by mail, common carrier, or hand delivery to retail outlets in Missouri and elsewhere. 1

The Director of Revenue sought to impose a use tax on the price paid by appellant to the binders. The appellant challenged…