Duluth Steel Fabricators, Inc. v. Commissioner of Taxation

Duluth Steel Fabricators, Inc. (Dúluth Steel), by writ of certiorari, challenges the judgment of the Tax Court that it is liable for sales taxes on materials sold by it to general contractors. We affirm.

Duluth Steel is in the business of fabricating structural steel to be installed by others on a variety of construction projects. Its services may be summarized as follows:(1) Duluth Steel makes decisions regarding settings, including their placement, number, and size, and instructs the general contractor accordingly.(2) Duluth Steel designs and furnishes detailed drawings concerning all clips,…