City and County of Denver, Colorado; Brendan Hanlon in His Official Capacity as the Chief Financi — Gabriel, J…

Summary

Justice Gabriel dissented from the conclusion that online travel companies furnished lodging and therefore qualified as vendors responsible for collecting Denver's lodging tax. The dissent would interpret the ordinance as requiring the provision of an actual room or accommodation, which the companies did not provide, and would consequently exclude their customer fees from the taxable purchase price. Justice Hood, concurring in the judgment, agreed with the result but would hold that the ordinance unambiguously required the companies to collect tax on the entire purchase price.