Carfax, Inc. v. Director of Revenue

CourtSupreme Court of Missouri
DecidedSeptember 13, 2022
DocketSC99367
StatusPublished

This text of Carfax, Inc. v. Director of Revenue (Carfax, Inc. v. Director of Revenue) is published on Counsel Stack Legal Research, covering Supreme Court of Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carfax, Inc. v. Director of Revenue, (Mo. 2022).

Opinion

SUPREME COURT OF MISSOURI en banc

CARFAX, INC., ) Opinion issued September 13, 2022 ) Respondent, ) ) v. ) No. SC99367 ) DIRECTOR OF REVENUE, ) ) Appellant. )

PETITION FOR REVIEW OF A DECISION OF THE ADMINISTRATIVE HEARING COMMISSION The Honorable Renee T. Slusher, Commissioner

The Director of Revenue seeks review of the Administrative Hearing

Commission’s (“AHC’s”) decision that the purchases by Carfax, Inc. (“Carfax”), of

certain equipment (the “Disputed Equipment”) used to create Vehicle History Reports

(“VHRs”) were exempt from sales and use taxes under sections 144.030.2(5) 1 and

144.054.2 because Carfax used such equipment to “manufacture” VHRs. This Court

holds that Carfax does not use the Disputed Equipment to manufacture VHRs for

1 All statutory references are to RSMo 2016 unless otherwise noted. However, see n.4 for an explanation as to the applicable versions of sections 144.030.2(5) and 144.054.2. purposes of these statutes. Accordingly, the AHC’s decision is vacated, and the cause is

remanded for further proceedings consistent with this opinion.

Background

Carfax is in the business of selling VHRs to consumers and car dealers. A VHR is

a report generated for a specific vehicle providing information about that vehicle’s

history, such as ownership and title history, mileage information, accident history,

previous maintenance and repairs, and manufacturer recall notices. A VHR also may

include Carfax’s own insights, including how much previous owners drove the vehicle

compared with the industry average, explanations of confusing title information, whether

a vehicle was located in an area where flooding occurred, and whether the vehicle’s oil

changes followed the manufacturer’s recommendations.

To create a VHR, Carfax first obtains as much raw data as it can from

approximately 112,000 sources, including sources such as state departments of motor

vehicles, state police databases, manufacturers, car dealers, after-market service shops,

insurance companies, vehicle repair centers, auctions, inspection sites, and other sources.

It stores this data in a 600-square-foot server room in Columbia, Missouri. Carfax then

performs an automated data cleansing process to remove incorrect or inconsistent entries

from this data. It then uses its own proprietary systems to organize and merge this new

data into its database.

When Carfax receives a request for a VHR concerning a particular vehicle, it

extracts only the information from its database pertaining to that vehicle. It warns

customers that the VHR reflects only the data supplied to Carfax and Carfax does not

2 guarantee either that the VHR contains all of the information relevant to that particular

vehicle or that the information provided is accurate. There are vehicles for which Carfax

never receives a VHR request, and there are instances in which Carfax extracts multiple

VHRs over time for the same vehicle. A VHR for a particular vehicle may vary from a

later VHR for the same vehicle if Carfax obtained additional data in the interim.

In October 2016, the Director of Revenue notified Carfax it was selected for an

audit for sales and use taxes due between 2013 and 2016. The Director determined

Carfax did not use the Disputed Equipment 2 to “manufacture” VHRs; therefore, its

purchase of that equipment was not exempt from sales and use taxes. Based on this

determination, the Director assessed $106,161.56 in taxes and interest. That amount also

included an additional five percent because the Director had audited Carfax for the years

prior to 2013, rejected Carfax’s argument that it owed no sales or use taxes for equipment

purchased that it used to “manufacture” VHRs, 3 and there had been no material change in

Carfax’s operations.

Carfax appealed the Director’s decision to the AHC. The AHC found Carfax’s

purchases of the Disputed Equipment were exempt from sales and use taxes under both

2 The Disputed Equipment was itemized in an exhibit before the AHC, but it generally includes servers, networking equipment, software, SAN drives, conferencing equipment, UPS devices, workstations, and related equipment. All these items were purchased between December 12, 2013, and September 30, 2016, and all of them were used in creating VHRs, with the exception of the video conferencing equipment items that were used for intraoffice communication, education, and training. 3 Carfax appealed this prior assessment to the AHC, which resulted in a settlement between the parties on October 31, 2016.

3 section 144.030.2(5) and section 144.054.2 4 because Carfax used that equipment directly

in “manufacturing” VHRs. The Director filed a petition for review with this Court

pursuant to section 621.189.

Analysis

This Court has exclusive appellate jurisdiction in all cases involving the

construction of state revenue laws, Mo. Const. art. V, § 3, and this Court’s standard for

reviewing AHC decisions involving sales and use (and other) taxes is well established:

“This Court will affirm a decision of the AHC if it: (1) is authorized by law; (2) is supported by competent and substantial evidence on the whole record; (3) does not violate mandatory procedural safeguards; and (4) is not clearly contrary to the General Assembly’s reasonable expectations.” Bus. Aviation, LLC v. Dir. of Revenue, 579 S.W.3d 212, 215 (Mo. banc 2019); § 621.193; Mo. Const. art. V, § 18. This Court does not uphold a decision of the AHC if it is “arbitrary, capricious, unreasonable, unlawful, or in excess of jurisdiction.” Myron Green Corp. v. Dir. of Revenue, 567 S.W.3d 161, 164 (Mo. banc 2019). This Court reviews the AHC’s legal decisions de novo. Id. “This Court is not bound by the [AHC]’s interpretation and application of the law.” Gervich v. Condaire, Inc., 370 S.W.3d 617, 620 (Mo. banc 2012).

“Taxing statutes must be strictly construed in favor of the taxpayer and against the taxing authority.” Bartlett Int’l, Inc. v. Dir. of Revenue, 487 S.W.3d 470, 472 (Mo. banc 2016). “Tax exemptions or exclusions, on the other hand, must be strictly construed against the taxpayer, and any doubt must be resolved in favor of the application of the tax.” Id.

Dreyer Elec. Co., LLC v. Dir. of Revenue, 603 S.W.3d 297, 301 (Mo. banc 2020)

(alteration in original).

4 Though the statutory language at issue appeared in slightly different subsections during the purchase period, the exact same language is now contained in sections 144.030.2(5) and 144.054.2, RSMo Supp. 2018. Both parties appear to have cited the newer statutes in their briefs. For ease of reference and because the language at issue remains the same, all statutory references to sections 144.030.2(5) and 144.054.2 are to RSMo Supp. 2018.

4 Carfax claims, and the AHC found, that its purchases of the Disputed Equipment

were exempt from sales and use taxes under either section 144.030.2(5) or section

144.054.2 or both. Section 144.030.2(5) provides certain purchases are exempt from

sales (and, therefore, use) tax:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson Excavating Co. v. Administrative Hearing Commission
646 S.W.2d 48 (Supreme Court of Missouri, 1983)
West Lake Quarry & Material Co. v. Schaffner
451 S.W.2d 140 (Supreme Court of Missouri, 1970)
Branson Properties USA, L.P. v. Director of Revenue
110 S.W.3d 824 (Supreme Court of Missouri, 2003)
Unitog Rental Services, Inc. v. Director of Revenue
779 S.W.2d 568 (Supreme Court of Missouri, 1989)
Wilson & Co., Inc. v. Department of Revenue
531 S.W.2d 752 (Supreme Court of Missouri, 1976)
Utilicorp United, Inc. v. Director of Revenue
75 S.W.3d 725 (Supreme Court of Missouri, 2001)
Heidelberg Central, Inc. v. Director of Department of Revenue
476 S.W.2d 502 (Supreme Court of Missouri, 1972)
Sipco, Inc. v. Director of Revenue
875 S.W.2d 539 (Supreme Court of Missouri, 1994)
House of Lloyd, Inc. v. Director of Revenue
824 S.W.2d 914 (Supreme Court of Missouri, 1992)
Concord Publishing House, Inc. v. Director of Revenue
916 S.W.2d 186 (Supreme Court of Missouri, 1996)
L & R EGG CO. v. Director of Revenue
796 S.W.2d 624 (Supreme Court of Missouri, 1990)
Galamet, Inc. v. Director of Revenue
915 S.W.2d 331 (Supreme Court of Missouri, 1996)
Business Aviation, LLC and Vaughn C. Zimmerman v. Director of Revenue
579 S.W.3d 212 (Supreme Court of Missouri, 2019)
Myron Green Corporation v. Director of Revenue
567 S.W.3d 161 (Supreme Court of Missouri, 2019)
State ex rel. AMF Inc. v. Spradling
518 S.W.2d 58 (Supreme Court of Missouri, 1974)
Gervich v. Condaire, Inc.
370 S.W.3d 617 (Supreme Court of Missouri, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Carfax, Inc. v. Director of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carfax-inc-v-director-of-revenue-mo-2022.