United Hardware Distributing Co. v. Commissioner of Revenue

KELLY, Justice:

United Hardware Distributing Company sells hardware products on a cooperative plan to hardware retail dealers. United also provides advertising assistance, at cost, that includes monthly advertising circulars. The circulars are purchased by the individual dealers and may be mailed directly to the public, placed as inserts in newspapers, distributed door-to-door, or distributed in any other way the dealer wishes.

On July 22, 1977, the Commissioner of Revenue assessed United $13,195 for sales tax 1 on sales of circulars to dealers in Min nesota 2 for the period June 1,1974,…