City of Colorado Springs v. Investment Hotel Properties, Ltd.

I would affirm the court of appeals. Investment Hotel Properties, Ltd. v. City of Colorado Springs, 781 P.2d 113 (Colo.App.1989). The court of appeals, in my view, properly concluded that Investment Properties’ purchase of tangible personal property for the exclusive purpose of furnishing private guest rooms in a hotel owned and operated by Investment Properties was not taxable under the Colorado Springs Sales and Use Tax Ordinance. City Code § 7-2-101 to -1302. The issue in this case is whether property purchased at wholesale and used to furnish hotel guest rooms is exempt from use tax under…