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BTLG Table of Contents > Sales and Use Tax Annotations > S > 505.0000 Sales to the United States and Its Instrumentalities > Annotation 505.0605

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505.0000 Sales to the United States and Its Instrumentalities—Regulation 1614

Annotation 505.0605

(b) Agencies Not Qualifying for Exemption

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505.0605 Sale to Law Firm—Not U.S. Government. A company sold microfilm to a law firm handling a case for the FSLIC. The law firm believes that it is exempt from paying sales tax since they are working for a branch of the federal government.

The law firm is mistaken in the belief that the sales to them are exempt merely because they work for the FSLIC. Since the microfilm was sold to the law firm and not to the federal government, the exemption for sales to the federal government does not apply. Rather the microfilm sales were taxable sales to the law firm for the law firm's use in its performance of its contract with the FSLIC. The company's sales of the microfilm are subject to sales tax. 2/17/88.