Allied Collection Service, Inc. v. Indiana Department of State Revenue

ORDER ON PARTIES’ CROSS-MOTIONS FOR SUMMARY JUDGMENT

FISHER, J.

Allied Collection Service, Inc. (Allied) appeals the Indiana Department of State Revenue’s (Department) imposition of Indiana use tax on collection letters Allied purchased from an out-of-state vendor in 2003 and 2004 (the years at issue). The matter is currently before the Court on the parties’ cross-motions for summary judgment. The issue for the Court to decide is whether Allied acquired those letters in a taxable “retail unitary transaction.”

FACTS AND PROCEDURAL HISTORY

The following facts are undisputed. Allied is a licensed…