J. W. Jones Construction Co. v. Revenue Division, Department of Taxation & Revenue

OPINION

WALTERS, Judge.

This is an appeal from the Decision and Order of the Revenue Division, Department of Taxation and Revenue (Department) denying Jones Construction Company’s (Jones) protest to a resources excise tax assessment, a gross receipts tax assessment, and its claim for a refund of resources excise taxes already paid.

Jones is a highway builder under contract with the State Highway Department for construction of roads and highways. In 1977 the Department directed Jones to file resources excise tax returns for sand and gravel severed and used in its highway construction projects.…