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Renaissance Management Company12/30/2003
The plaintiff, Renaissance Management Company, Inc., appeals, pursuant to General Statutes § 12-422, from the judgment of the trial court, which dismissed its appeal from the determination by the defendant, the commissioner of revenue services, that during the audit period of October 1, 1993, through September 30, 1996, the plaintiff was not exempt from sales and use taxes on gross receipts derived from the furnishing of property management services. The plaintiff claims that the trial court improperly determined that it had failed to satisfy its burden of proving that the exemption described in General Statutes (Rev. to 1993) § 12-407 (8) and (9) includes theseparately stated expenses of employees who are not located at, and who do not solely devote their time to, a single housing project.
Our examination of the record and briefs and our consideration of the arguments of the parties persuade us that the judgment of the trial court should be affirmed. The issues were resolved properly in the trial court's concise and well reasoned memorandum of decision. Renaissance Management Co. v. Commissioner of Revenue Services, 48 Conn. Sup. 221, A.2d (2002). Because that memorandum of decision fully addresses all arguments raised in this appeal, we adopt it as a proper statement of the issues and the applicable law concerning those issues. It would serve no useful purpose for us to repeat the discussion contained therein. See Davis v. Freedom of Information Commission, 259 Conn. 45, 55-56, 787 A.2d 530 (2002).
The judgment is affirmed.
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