Sears, Roebuck & Co. v. Commissioner of Revenue

The plaintiff, Sears, Roebuck & Co. (Sears), appeals from a decision of the Appellate Tax Board (board) denying its claims for reimbursement of sales taxes it remitted to the Commonwealth from purchases of its products by customers using a private label credit card issued by Citibank, N.A. (Citibank), and who later defaulted on their accounts with the bank.

Facts. We summarize the background from the board’s findings based on the parties’ joint stipulation and their agreed statement of facts.2

*769Sears provided its customers the option of purchasing its products on credit with a private label…