Cowden & Sons Trucking, Inc. v. Indiana Department of State Revenue

FISHER, Judge.

Cowden & Sons Trucking, Inc. (Cowden) appeals the Indiana Department of Revenue's (Department) imposition of sales and use tax on money received from hauling services provided to its customers.

Facts

At the time of the assessment, Cowden, an Indiana corporation, was a motor carrier engaged in the business of transporting various materials, such as sand, gravel, stone, and agricultural lime, hereinafter referred to as "stone." Ninety-five percent (95%) of Cowden's business consisted of transporting stone for contractors. For these customers, Cowden usually hauled the stone from a…