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Business Taxes Law Guide—Revision 2024
Sales and Use Tax Annotations
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420.0000 Photographers, Photostat Producers, Photo Finishers and X-Ray Laboratories—Regulation 1528
Annotation 420.0155
(a) In General
420.0155 Microfilming Charges. Company A engages Company B to perform mail room services consisting of receiving, sorting, opening, and batching mail documents. A also engages Company C to microfilm documents. C is owned by B and uses the same employees to do the microfilming. The charge for microfilming is a taxable sale of tangible personal property and includes the charges for services that are part of that sale, such as related mail room services. However, the charge for the mail room services will not be subject to tax if: A contracts separately with B and C; statutory requirements have been met in forming B and C as separate entities; B and C's use of the same employees is in accordance with applicable law and with each company's by-laws; and the charge for the mail room services is not increased by decreasing the microfilming charge. 12/6/94.