Stoker Management, Inc. v. Sharp

KIDD, Justice.

This is a sales tax collection case arising under Texas Tax Code section 111.016 (West 1992). The State Comptroller of Public Accounts (“Comptroller”) audited Stoker Management, Inc. (“Stoker”) and determined that Stoker was responsible for remitting to the Comptroller the sales tax on services performed by its franchisees. The Comptroller assessed sales tax liability against Stoker in the amount of $169,408.92, inclusive of tax, penalty, and interest. Stoker disagreed with the assessment and filed a Petition for Rede-termination. A hearing was held before an administrative law…