DI Supply I, LLC and its Individual Members Missouri Cases

DI Supply I, LLC, which sells room furnishings to Drury Hotels, challenged a sales tax assessment, contending that its sales were exempt under the resale exemption because the hotels effectively resold the furnishings to guests. The Administrative Hearing Commission upheld the assessment. On review, the Missouri Supreme Court affirmed, clarifying that the sales tax resale exemption requires a transfer of title or ownership, not just the right to use, store, or consume the property. The Court concluded that prior jurisprudence had mistakenly applied use tax definitions to sales tax cases, and DI Supply failed to demonstrate a transfer of ownership to hotel guests.