Ex Parte Thompson Tractor Co., Inc.

FAULKNER, Justice.

This is a sales tax case in which Thompson Tractor Company (taxpayer) appealed an assessment by the State Department of Revenue (State) to the Circuit Court of Jefferson County. The circuit court confirmed the assessment. On appeal, the Court of Civil Appeals affirmed the circuit court’s judgment. Thompson Tractor Co. v. State of Alabama, 432 So.2d 493 (Ala.Civ.App.1982). Following a denial of taxpayer’s application for rehearing, we granted certiorari.

Taxpayer was a dealer in heavy equipment manufactured by the Caterpillar Tractor Company. In addition to selling equipment…