Richardson's Rv, Inc., Respondent (petitioner Below) v. Indiana Department of State Revenue, Petitioner (respondent…

Summary

The Indiana Supreme Court reversed the Tax Court’s summary judgment for Richardson's RV, holding that the Michigan deliveries were taxable because they were structured solely to avoid Indiana sales tax and lacked any legitimate business purpose. The Court entered summary judgment for the Department of State Revenue and remanded for a determination of the tax owed and whether any non‑tax business purpose existed for four out‑of‑state deliveries. The decision also affirmed the de novo standard for reviewing summary‑judgment rulings, with limited deference to the Tax Court.