Val-Pak of Central Connecticut North, Inc. v. Commissioner of Revenue Services

The principal issue in this tax appeal is whether a corporation that designs and orders advertising materials for cooperative direct mailing to private households has engaged in transactions that are subject

*738to the use tax, General Statutes § 12-411 (1).1 The defendant, the commissioner of revenue services, as a result of an audit for the years 1984 through 1989, initially concluded that the plaintiff, Val-Pak of Central Connecticut North, Inc., was hable for payment of the sales tax as a seller of tangible personal property.2 After a reassessment at the plaintiffs behest, the defendant…