Books-A-Million v. SCDOR

Syllabus

In this case arising from a sales tax audit by the South Carolina Department of Revenue (SCDOR), Books-A-Million, Inc. (BAM) appeals from the order of the Administrative Law Court (ALC) that upheld SCDOR's assessment of taxes, penalties, and interest against BAM for failing to include sales of the Millionaire's Club Memberships (Club Memberships) in BAM's gross proceeds of sales. BAM argues the ALC erred in finding (1) the amounts collected by BAM for Club Memberships are subject to sales tax (2) renewals of Club Memberships are subject to sales taxes and (3) the statutes are not ambiguous. We affirm.