Richard R. Sneary v. Director Revenue

This is an appeal from the decision of the administrative hearing commission. Richard R. Sneary, appellant, is an architect
licensed by the state of Missouri, doing business as Sneary Architectural Illustration. The director of revenue, respondent,
assessed sales tax on Sneary's sales of architectural illustrations that Sneary prepared and sold to architectural firms from
May 14, 1987, through February 28, 1991. Sneary challenged the assessment, arguing that the true object of the transactions
was the sale of his professional services rather than the illustrations themselves. The administrative hearing commission
upheld the assessment, concluding that the transactions involved the sale of tangible personal property and that the assessment
was not unexpected. That decision is affirmed. Architects traditionally prepared architectural illustrations as part of their professional services. Today, however, specialists
often prepare these illustrations. Architectural firms either employ specialists in-house or contract the project to third
parties such as Sneary.