Zip Sort, Inc. v. Commissioner of Revenue

OPINION

TOMLJANOVICH, Justice.

The relator, Zip Sort, Inc., filed claims for a refund of sales taxes imposed upon its purchase of two multi-line optical character readers (“character readers”) and a bar code sorter. Minnesota law allows taxpayers to receive a refund of state and local sales taxes paid pursuant to the purchase of “capital equipment,” which is defined in part as equipment that manufactures or' fabricates tangible personal property for- sale at retail. The Department of Revenue (“DOR”) concluded that Zip Sort uses the character readers and the bar code sorter to provide a service…