Hunkin-Conkey Const Co. v. Davis

26 Ohio Law. Abs. 263, 11 Ohio Op. 336, 1938 Ohio Misc. LEXIS 1150
CourtCuyahoga County Common Pleas Court
DecidedApril 11, 1938
DocketNo 445888
StatusPublished

This text of 26 Ohio Law. Abs. 263 (Hunkin-Conkey Const Co. v. Davis) is published on Counsel Stack Legal Research, covering Cuyahoga County Common Pleas Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hunkin-Conkey Const Co. v. Davis, 26 Ohio Law. Abs. 263, 11 Ohio Op. 336, 1938 Ohio Misc. LEXIS 1150 (Ohio Super. Ct. 1938).

Opinion

[264]*264OPINION

By MCMAHON, J.

This case reaches the court upon the petition of the plaintiffs, the answer of the defendants, stipulations, arguments and briefs. It is the claim of the plaintiffs, who are a great many in number, and-who are either contractors or sub-contractors, that they have entered into or are now obligated by construction contracts pursuant to which tangible personal property will be incorporated in the structures and through improvements, and which eventually become a part oi the real property; that said contracts are in existence with various political sub-divisions of the State of Ohio and the Federal government; that the funds necessary for the transaction of this work in whole or in part are furnished by the Federal government under the provisions of the act or acts of Congress; that certain fluids for the letting and performance oí said contracts and all things connected therewith have been and are now. under the control and supervision of the Federal government; that all of said contracts were in the main executed and delivered shortly prior to December 20, 1935, and that it was the intention of such contractors that said contracts should begin after that date; that each and all of said contracts will be performed, and that the tangible personal property which will be incorporated into those structures so contemplated will be purchased and placed in those structures subsequent to December 20th, 1935.

The Tax Commission of Ohio contends that ail of such personal property is subject to the payment of the retail sales tax when purchased and used subsequent to December 20, 1935, notwithstanding the contracts entered into were prior ‘thereto.

The plaintiffs in this action are licensed vendors and it is their intention to issue re-sale certificates to the suppliers of such tangible personal property and will furnish exemption certificates as provided by the sales act and regulations of the Tax Commission.

The plaintiffs herein pray the court for a declaratory judgment as to their rights, their status and their legal relations under §5546-1 GC and all of the related sections pertaining to the retail sales act; of Ohio.

The Tax Commission likewise ask the court for a declaratory judgment on the same question and contend that said contractors or said plaintiffs are not exempt from the tax provided for in §5546-1, et seq., GC.

The issue then presented is as follows;

Is a contractor (a licensed vendor), who entered into a “construction contract” prior to December 20, 1935, of the type described in §5546-1, GC, obligated to pay, from his own funds without recourse, the retail sales tax on tangible personal property purchased by and delivered to him subsequent to December 20, 1935, for use or consumption in the performance of such a contract, or may he, in lieu of such payment, furnish exemption or resale certificates?

The pertinent portion of §5546-1, GC, as amended and effective December 20, 1,935, is, sis follows:

[265]*265“‘Sale’ and ‘selling’ include all transactions whereby title or possession, or both, of tangible personal property, is or is to be transferred, or a license to use or consume tangible personal property is granted, for a consideration in any manner, whether absolutely or conditionally, whether for a price or rental, in money or by exchange or barter, and by any means whatsoever. A construction contract, pursuant to which tangible personal property is or is to be incorporated into a structure or improvement on becoming a part of real property or is or is to be used or consumed in perofrming such contract shall, if the consideration lor such incorporation, use or consummation is agreed upon, charged or paid separately from the consideration for the.performance of the other obligations of such construction contract, constitute a sale of such tangible personal property for the purpose of this act.”

It has been conceded that had these contracts been dated subsequent to December 20, 1935, the contractors would not be subject to tax, that the contracts do not exactly specify the property to be transferred, nor do they specify maximum and minimum quantities of goods. The court then is of the opinion that the legal question involved in this law suit turns solely and only up”on the date of all of these contracts.

The court learns that in an opinion, No. 3961, under date of February 23, 1935, the Attorney General of Ohio rendered an opinion, the basis of which was that under contracts of this kind “that there is no fixed amount of tangible personal property contracted for upon which to compute the tax” and that ruling has been adopted by and acted upon by the Tax Commission.

The Attorney General also in one of his opinions, No. 4137 under date of April 10, 1935 ruled that:

“When sales of tangible personal property in this state are effected, the question of when title passes is one of fact. In determining the question the controlling fact- or is the intention of the parties which should be ascertained by consideration of the terms of the contract, the conduct of the parties, usages of trade, and the circumstances of the case aided by certain' recognized presumptions of law and rules of law as contained m the so-called Uniform Sales law as it is in force in this state:”

This court is in accord with that principle because under the sales act title does not pass when the contract is made unless the contract is for specific goods in a deliverable state. (§8399 GC). This is almost fundamental law. Otherwise there could be no definite tangible chattel, there could be no fixed consideration, and there could be no meeting of the minds of the parties to the contract.

It is a matter of common knowledge that construction contracts never call for any identical specific chattels in a deliverable state. Construction contractors do not carry stocks of materials on hand. They go about the performance of their contracts and purchase their requirements as needed as the work progresses. At the time of the signing or making of the contract they could not pass title even if they desired to do so to chattels because they do not have such chattels, nor do they have title to such chattels. Therefore,- any application of the so-called intention test in this case should not be applied.

The court, is of the opinion that the law in deciding a situation of this kind should receive reasonable, practical and workable construction. There are possibilities that these contracts so entered into prior to the taking effect of this act might never have been performed. Buildings might never have been erected. The contractors do not own the materials when they make the contracts and even if quantities are mentioned in the contracts they axe estimates only There is nothing fixed, set, nor determined. There is the chance of the fluctuation of prices from the time of the making of the contract and of the buying of the materials which are to be used in the structures. The sales tax should be based upon fact, that is, sale price, and not market price at some future time.

[266]*266[265]*265The Tax Commission, through the Attorney General’s office, in its brief places great reliance upon the decision of the Franklin County Common Pleas Court in the case of The Capital City Coal Company v The Tax Commission, decided, September 28, 1936.

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Bluebook (online)
26 Ohio Law. Abs. 263, 11 Ohio Op. 336, 1938 Ohio Misc. LEXIS 1150, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hunkin-conkey-const-co-v-davis-ohctcomplcuyaho-1938.