Books-A-Million, Inc. v. South Carolina Department of Revenue

Syllabus

For $25 per year, customers of Books-A-Million (\taxpayer\) can become members in the \Millionaires Club\ to receive retail discounts. These memberships became the subject of a tax audit by the South Carolina Department of Revenue and, as a result, taxpayer was assessed nearly a quarter-of-a-million dollars in back taxes. The Administrative Law Court (\ALC\) agreed with the Department's assessment, and the court of appeals affirmed on the grounds that the \proceeding or accruing\ language of our sales tax act includes the returns from Millionaire's Club sales. We affirm.