Slater Corp. v. South Carolina Tax Commission

Sanders, Chief Judge:

This is an action by appellant Slater Corporation against respondent South Carolina Tax Commission pursuant to section 12-47-440 of the 1976 Code of Laws of South Carolina. Slater seeks a refund of certain sales taxes which it paid as a buyer of food supplies from various sellers during the period 1969 through 1978. The trial judge denied the refund. We reverse.

Slater is a food service company which prepares and serves meals at a number of educational institutions in South Carolina. In February 1969, the Commission issued a ruling to Clemson University recognizing that a…