Matrix Funding Corp. v. Auditing Division of the Utah State Tax Commission

OPINION

BENCH, Judge:

Matrix Funding Corporation (Matrix) appeals an order from the Utah State Tax Commission (Commission) holding that a transaction between Matrix and one of its Utah customers (Customer) requires payment of sales tax. We affirm.

FACTS

Matrix and Customer entered into a Sale and Leaseback Agreement (Sale Agreement), which provided that Matrix would purchase equipment from Customer with title passing to Matrix. Customer then agreed to lease the equipment back for a period of sixty months, giving Customer an option to purchase the equipment at the end of the term, which is…