International Thomson Publishing, Inc. v. Tracy

We find the BTA’s decision is reasonable and lawful and, thus, affirm it.

South-Western first argues that no taxable event occurs when it withdraws the exam copies from its resale inventory and gives them to out-of-state recipients. Nevertheless, we agree with the commissioner that South-Western’s handling of these books in Ohio constituted a taxable event.

In Norandex, Inc. v. Limbach (1994), 69 Ohio St.3d 26, 29-30, 630 N.E.2d 329, 332, we held, for cases involving the dormant Commerce Clause, that:

“[W]e must find a taxable event, in this case a use of the property, and apply the Complete…