Section references are to Title 2 of the Texas Tax Code, and Rule references are to Title 34, Texas Administrative Code. Notice has been taken of all Comptroller's records pertinent to this case. The record was held open for a period of time so the parties could brief the penalty waiver issue. The opinion below treats only the remaining contested issue.
Petitioner prints grocery circulars, school catalogs, and miscellaneous other information documents.
Petitioner's redetermination request resulted in the instant proceeding. The binder was thereafter taken to Atlanta, Georgia, and installed at a location there. Both Company B and Company A are printing equipment dealers. Petitioner accrued and remitted tax on its own return on that portion of the purchase price of the Saddle Stitcher that represented the difference between the purchase price and the amount received for the Binder. Petitioner's representative and witness was not involved in Petitioner's purchase of the saddle stitcher.