On August 26, 2026, the Missouri Department of Revenue issued a letter ruling concluding that “charges for providing medical records on a CD are not subject to Missouri sales tax.” The letter ruling applicant was in the business of retrieving, compiling, reproducing, and furnishing medical records. The applicant in some instances furnished the requested medical records via CDs. Relying on the true object doctrine, the Department determined that these charges were not taxable as sales of tangible personal property. The customers purchased commingled tangible and intangible personal property. The Department concluded that the transaction was not subject to sales tax because “the true object was the obtaining of the services and records rather than obtaining the CD as a finished product.” The tangible CD was “merely and exclusively a means of conveyance of the records.”



