In an earlier post we mused about what the IA DOR must have been thinking when it decided to impose the Pumpkin Tax. Well, the pen is mightier than the sword I guess. The Governor must have read our blog and decided to intervene.
According to CCH, "Governor Chet Culver has directed the Iowa Department of Revenue to suspend the collection of sales tax on pumpkins."
This directive was issued on October 31, though, so the tax savings would have been minimal, but the Governor must have been in a merry mood because he also directed that "Taxpayers who have paid the tax can apply for a refund with the Department."
Now, I think pumkins should be exempt everywhere, but, one must ask, how does the Governor have this type of authority anyway?
Friday, November 9, 2007
Amazon.com May Incur the Wrath of the Media
Misunderstanding the tax law and how it works, does not mean a newspaper editor will refrain from bashing a company. Dean Baker wrote an editorial for the Chicago Sun Times on November 4, 2007, entitled "How Amazon got rich on our tax dollars". The title presages the content. Here's a few of the blistering quotes:
Whenever a writer uses the word "loophole", it's never good for the company being attacked.
But isn't this a "win-win" situation? The company benefits and the customer benefits, right? I think so, but what I think doesn't add up to much. What the buying public thinks is a big deal. Will they be influenced by this type of vitriol?
- "The business press has written numerous stories explaining how Jeff Bezos, Amazon's founder and CEO, is a truly brilliant businessman. This may well be true, but the secret of his success is not in the futuristic world of the Internet, rather it's in the old-fashioned world of tax avoidance."
Whenever a writer uses the word "loophole", it's never good for the company being attacked.
- "Thanks to a loophole in the law, Amazon is not required to collect sales tax on its sales. Amazon effectively splits this tax bonanza with its customers, giving them an incentive to keep coming back."
But isn't this a "win-win" situation? The company benefits and the customer benefits, right? I think so, but what I think doesn't add up to much. What the buying public thinks is a big deal. Will they be influenced by this type of vitriol?
- "While Amazon and its customers can both be happy about this situation, this is not a classic win-win story. The sales diverted to Amazon and other Internet retailers came at the expense of old-fashioned brick-and-mortar retailers who haven't mastered the 21st century skill of tax avoidance. These old-timers are losing business and profits because of Amazon's tax subsidy.
State and local governments are also losing tax revenue. This means these governments must either cut back services provided to their residents or they must raise other taxes. Of course, buying goods over the Internet does not reduce the demand for services from state and local governments. So, when politicians promise not to tax the Internet, they are in effect promising to impose higher taxes on items other than Internet purchases."
Do You Have Nexus in IL?
Illinois issued a recent letter ruling with some specific examples of activities that create sales tax nexus in their state. And I quote:
That's the first prong, it's their commenary on the second prong of the test that is interesting.
- "The United States Supreme Court in Quill Corp. v. North Dakota, 112 S.Ct. 1904 (1992), set forth the current guidelines for determining what nexus requirements must be met before a person is properly subject to a state's tax laws. The Supreme Court has set out a 2-prong test for nexus.
- "The first prong is whether the Due Process Clause is satisfied. Due process will be satisfied if the person or entity purposely avails itself or himself of the benefits of an economic market in a forum state. Quill at 1910. "
That's the first prong, it's their commenary on the second prong of the test that is interesting.
- "The second prong of the Supreme Court's nexus test requires that, if due process requirements have been satisfied, the person or entity must have physical presence in the forum state to satisfy the Commerce Clause. A physical presence is not limited to an office or other physical building. Under Illinois law, it also includes the presence of any agent or representative of the seller. The representative need not be a sales representative. Any type of physical presence in the State of Illinois, including the vendor's delivery and installation of his product on a repetitive basis, will trigger Use Tax collection responsibilities. "
Officer Liable for Unpaid Tax Even Though Company Run by Independent Contractor
In a recent administrative hearing in Illinois, an owner of a car dealership who did not actually run the day-to-day operations of the dealership was held liable for taxes not remitted.
This is a tough case. There was this car dealer who wanted to sell his dealership to another company. The other company was going to have to be approved by Chrysler. So while the application was in process, the two parties executed a management agreement. The new company would come in and run the place like they owned it. The management agreement covered the tax issue -- it would be the responsibility of the new company. You'd think you were in good shape from a sales tax standpoint. But not in IL.
But the new operator didn't remit the tax collected. The prior owner claims he had no idea that the tax wasn't sent in. On audit, IL assesses the prior owner saying he was a "responsible officer". IL won the case at the administrative level. The government always seems to get their money, and they get it from the easiest source. (Illinois Department of Revenue, IL --Administrative Hearing Decision No. ST 07-13)
This is a tough case. There was this car dealer who wanted to sell his dealership to another company. The other company was going to have to be approved by Chrysler. So while the application was in process, the two parties executed a management agreement. The new company would come in and run the place like they owned it. The management agreement covered the tax issue -- it would be the responsibility of the new company. You'd think you were in good shape from a sales tax standpoint. But not in IL.
But the new operator didn't remit the tax collected. The prior owner claims he had no idea that the tax wasn't sent in. On audit, IL assesses the prior owner saying he was a "responsible officer". IL won the case at the administrative level. The government always seems to get their money, and they get it from the easiest source. (Illinois Department of Revenue, IL --Administrative Hearing Decision No. ST 07-13)
Media Thinks Manufacturing Gets A "Whopping" Tax Break
An article in the Atlanta Journal and Constitution caught my eye because it was all about how the medical industry is a big "winner" because it will retain some sales tax exemptions. According to the AP writer Shannon McCaffrey, the industries that contributed the PAC got the best deductions. Then there was this throw away line that reveals some bias, maybe, and lack of understanding of double taxation certainly:
"The biggest single exemption in Richardson's plan is on the sale of raw materials to manufacturers worth a whopping $3.2 billion."
Always interesting how things are viewed by the opinion shapers.
"The biggest single exemption in Richardson's plan is on the sale of raw materials to manufacturers worth a whopping $3.2 billion."
Always interesting how things are viewed by the opinion shapers.
What's Going on in Michigan?
On October 2, 2007, the Governor signed a bill imposing a sales tax on 23 new services to be effective December 1, 2007. These services are:
-- business service center services;
-- consulting services;
-- investment advice services;
-- janitorial and landscaping services;
-- warehousing and storage services;
-- packaging and labeling services;
-- document preparation services; and
-- many personal services, such as concierge and psychic services.
Now they're getting cold feet. That's good.
So then on November 1, the Michigan Senate has passed a bill (S.B. 845) to postpone the imposition of the new 6% use tax on services from December 1, 2007, to December 20, 2007.
According to CCH, the goal of this new bill is to provide the Legislature additional time to find an alternative to the new tax.
Then the Michigan Senate has passed S.B. 838, a bill to repeal the imposition of the new 6% use tax on selected services immediately when the tax takes effect on December 1, 2007. S.B. 845, a bill to postpone the imposition of the new tax from December 1, 2007, to December 20, 2007, can only take effect if S.B. 838 is enacted.
Sounds to me like it's back to the drawing board for MI, if the Governor signs this bill.
The Detroit Free Press even editorialized on the new tax law, saying it is "capricious, complicated and potentially burdensome to businesses big and small. It taxes an odd mix of services and exempts others, based, evidently, on legislative perceptions of what sort of spending for services is discretionary as opposed to necessary -- and on who had the loudest lobbyists when the tax plan was being duct-taped together."
Ouch.
They're saying it's "time to bring serious proposals out into public view, with plenty of time for everyone to dissect them, discuss them, and, if needed, present them to voters next August or November."
Let's see how things develop there.
-- business service center services;
-- consulting services;
-- investment advice services;
-- janitorial and landscaping services;
-- warehousing and storage services;
-- packaging and labeling services;
-- document preparation services; and
-- many personal services, such as concierge and psychic services.
Now they're getting cold feet. That's good.
So then on November 1, the Michigan Senate has passed a bill (S.B. 845) to postpone the imposition of the new 6% use tax on services from December 1, 2007, to December 20, 2007.
According to CCH, the goal of this new bill is to provide the Legislature additional time to find an alternative to the new tax.
Then the Michigan Senate has passed S.B. 838, a bill to repeal the imposition of the new 6% use tax on selected services immediately when the tax takes effect on December 1, 2007. S.B. 845, a bill to postpone the imposition of the new tax from December 1, 2007, to December 20, 2007, can only take effect if S.B. 838 is enacted.
Sounds to me like it's back to the drawing board for MI, if the Governor signs this bill.
The Detroit Free Press even editorialized on the new tax law, saying it is "capricious, complicated and potentially burdensome to businesses big and small. It taxes an odd mix of services and exempts others, based, evidently, on legislative perceptions of what sort of spending for services is discretionary as opposed to necessary -- and on who had the loudest lobbyists when the tax plan was being duct-taped together."
Ouch.
They're saying it's "time to bring serious proposals out into public view, with plenty of time for everyone to dissect them, discuss them, and, if needed, present them to voters next August or November."
Let's see how things develop there.
Handing Out Coupons in CA Gives You Nexus There?
You know Barnes & Noble, the big box bookstore operating all across the US. They just won a nice victory against the CA SBE in the CA Superior Court (Barnesandnoble.com LLC v. State Board of Equalization, California Superior Court, San Francisco County, Case No. CGC-06-456465, October 11, 2007). They are not a client of ours, but according to the published court case, here are some relevant facts regarding the corporate structure, during the applicable tax period.
They had a parent company, let's call it BN. BN had a number of subsidiaries. These included subs we'll call Booksellers (owned 100%), BN.com (owned 100%) and BN.com LLC (owned 40% by BN and 40% by another unrelated company and 20% by BN.com. That's a mindful, but it's important. BN.com LLC is the plaintiff in this case, at it is the Internet retailer. Booksellers (the 100% sub of BN) is the company that operates the actual brick and mortar stores. It is not an owner of the plaintiff, but it shares some common owners.
They were careful to set up this Internet reseller so that it would not have sales tax nexus in other states. They had no physical presence in CA for one thing. They were housed in a separate building from other BN entities, the management of the plaintiff was different and distinct. And finally, the plaintiff did not allow its customers to return books or other products.
States have used these factors and others to argue that while a dotcom entity itself may not have a physical presence in their state, they are using their sister companies as agents in the state. That agency relationship is what gives the states the right to force the dotcom to collect sales tax. California was successful in the Borders Online case, but in that situation, the online entity had substantially overlapping boards of directors, and perhaps most importantly, the brick and mortar stores accepted returns and their empoyees actively solicited business for the online entity.
Well the plaintiff in this case did not meet any of the criteria commonly used by the states. But that didn't stop CA from going after them. So what was the plaintiff doing that made CA think they should register and collect tax? Not much. But CA thought it was sufficient.
BN.com LLC, the Internet retailer, put coupons in Bookseller's customers' shopping bags adverstising the existence of the dotcom and offering a discount on online purchases. That's it. They didn't even ask Booksellers to stuff the coupons in the bags -- they hired an independent vendor to do that.
CA argued that on the "basis of the coupons alone" Plaintiff was "retailer engaged in business in the state" with a "substantial nexus in California". They contended that Booksellers acted as Plaintiff's agent.
Does that seem like a reach or what?
The Superior Court said this was not enough of a connection or enough of a relationship to call it an "agency relationship". They specifically said that "the fact that Plaintiff and Booksellers are sister corporations does not support a finding of fact that Booksellers as Plaintiff's agent." They also pointed out -- much to the chagrin of CA, I'm sure, that the "concept of agency requires something significantly more" than passing out coupons. They say this, and this helps: "An essential element is that the agent (or representative) must have the authority bind the principal..."
That's the good news.
The bad news is that CA thought they had a good case here. The bad news is that what this case really says is that you really have to go to great lengths not to have nexus. I think most dotcom affiliates of brick and mortar retailers are concluding that the risk of losing a case like this is not worth the effort of setting the structure up in just the right way to avoid a finding of nexus.
My opinion is that more and more people buy stuff online because its convenient to do so. Being able to return something you don't like, or doesn't work to a brick and mortar makes many people more inclined to shop at a brick and mortar dotcom affiliate, even if they still have to pay tax to do so.
We have a copy of the case available on our website if you'd like it.
They had a parent company, let's call it BN. BN had a number of subsidiaries. These included subs we'll call Booksellers (owned 100%), BN.com (owned 100%) and BN.com LLC (owned 40% by BN and 40% by another unrelated company and 20% by BN.com. That's a mindful, but it's important. BN.com LLC is the plaintiff in this case, at it is the Internet retailer. Booksellers (the 100% sub of BN) is the company that operates the actual brick and mortar stores. It is not an owner of the plaintiff, but it shares some common owners.
They were careful to set up this Internet reseller so that it would not have sales tax nexus in other states. They had no physical presence in CA for one thing. They were housed in a separate building from other BN entities, the management of the plaintiff was different and distinct. And finally, the plaintiff did not allow its customers to return books or other products.
States have used these factors and others to argue that while a dotcom entity itself may not have a physical presence in their state, they are using their sister companies as agents in the state. That agency relationship is what gives the states the right to force the dotcom to collect sales tax. California was successful in the Borders Online case, but in that situation, the online entity had substantially overlapping boards of directors, and perhaps most importantly, the brick and mortar stores accepted returns and their empoyees actively solicited business for the online entity.
Well the plaintiff in this case did not meet any of the criteria commonly used by the states. But that didn't stop CA from going after them. So what was the plaintiff doing that made CA think they should register and collect tax? Not much. But CA thought it was sufficient.
BN.com LLC, the Internet retailer, put coupons in Bookseller's customers' shopping bags adverstising the existence of the dotcom and offering a discount on online purchases. That's it. They didn't even ask Booksellers to stuff the coupons in the bags -- they hired an independent vendor to do that.
CA argued that on the "basis of the coupons alone" Plaintiff was "retailer engaged in business in the state" with a "substantial nexus in California". They contended that Booksellers acted as Plaintiff's agent.
Does that seem like a reach or what?
The Superior Court said this was not enough of a connection or enough of a relationship to call it an "agency relationship". They specifically said that "the fact that Plaintiff and Booksellers are sister corporations does not support a finding of fact that Booksellers as Plaintiff's agent." They also pointed out -- much to the chagrin of CA, I'm sure, that the "concept of agency requires something significantly more" than passing out coupons. They say this, and this helps: "An essential element is that the agent (or representative) must have the authority bind the principal..."
That's the good news.
The bad news is that CA thought they had a good case here. The bad news is that what this case really says is that you really have to go to great lengths not to have nexus. I think most dotcom affiliates of brick and mortar retailers are concluding that the risk of losing a case like this is not worth the effort of setting the structure up in just the right way to avoid a finding of nexus.
My opinion is that more and more people buy stuff online because its convenient to do so. Being able to return something you don't like, or doesn't work to a brick and mortar makes many people more inclined to shop at a brick and mortar dotcom affiliate, even if they still have to pay tax to do so.
We have a copy of the case available on our website if you'd like it.
What's the Rush to Tax? Maryland Trying to Solve Deficit
So Maryland has a projected $1.5B deficit they're trying to deal with. What creative approach do they conceive? Increase taxes. The Governor wants to raise the tax rate to 6% from 5% and tax a raft of new types of businesses. But these things have to be done with input from the taxed businesses. But in politics, you have to strike while the iron is hot. Some legislators, don't like it though.
I like this quote from an impassioned Sen. E.J. Pipkin, R-Upper Shore, as quoted in the Maryland Daily Record who said the proposal was moving too quickly and there should be more time for people to respond to the proposal and for legislators to clarify the intent of the legislation. “What’s the rush this week …? You’ve just included millions of people into a tax bill, and you didn’t get the input of the industry, and you’re saying we didn’t have time.”
Even Maryland Comptroller Peter Franchot is quoted as saying “It’s an example of what happens when you try to implement tax policy at warp speed in a highly charged political environment... adding a tax provision of this magnitude to legislation at the 11th hour — without the courtesy of advance notice, the benefit of meaningful public input or sufficient understanding of its effects — plays into the hands of those who would unfairly question Maryland’s business climate,” Franchot wrote.
It appears that Maryland may end up taxing "computer services". That's always problematic. A number of states have tried that and always find that the big difficulty is determining whether to tax is due and to what extent on services that were performed out-of-state for in-state companies.
I like this quote from an impassioned Sen. E.J. Pipkin, R-Upper Shore, as quoted in the Maryland Daily Record who said the proposal was moving too quickly and there should be more time for people to respond to the proposal and for legislators to clarify the intent of the legislation. “What’s the rush this week …? You’ve just included millions of people into a tax bill, and you didn’t get the input of the industry, and you’re saying we didn’t have time.”
Even Maryland Comptroller Peter Franchot is quoted as saying “It’s an example of what happens when you try to implement tax policy at warp speed in a highly charged political environment... adding a tax provision of this magnitude to legislation at the 11th hour — without the courtesy of advance notice, the benefit of meaningful public input or sufficient understanding of its effects — plays into the hands of those who would unfairly question Maryland’s business climate,” Franchot wrote.
It appears that Maryland may end up taxing "computer services". That's always problematic. A number of states have tried that and always find that the big difficulty is determining whether to tax is due and to what extent on services that were performed out-of-state for in-state companies.
Friday, November 2, 2007
Manufacturers in Missouri Take Note
New Sales Tax Exemption for Manufacturers
Governor Matt Blunt signed the bill June 13, 2007, saying, “Manufacturing is a vital part of our diverse economy, and this will help level the playing field for Missouri manufacturers.” Effective August 28, 2007, Senate Bill 30 exempts from state tax (4.225 percent) and local use tax, but not local sales tax: (note the exemption is for local use tax but not local sales tax)
All of the above may be exempt if they are:
Examples of Activities That Are Not "Manufacturing, Processing, Compounding,
Mining, or Producing a Product:"
A. Preparing a meal in a restaurant.
B. Constructing a road, building, or other fixed structure.
C. Florist activities.
Examples of Activities That Are "Manufacturing, Processing, Compounding,
Mining, or Producing a Product:"
A. Making cabinets and countertops.
B. Making modular homes.
C. Making pre-fabricated steel or concrete products.
D. Preparing framed photographs or pictures.
E. Testing of manufacturing equipment before it is installed.
F. Commercial printing.
G. Producing a wireless or landline based telephone call.
H. Bakeries.
Governor Matt Blunt signed the bill June 13, 2007, saying, “Manufacturing is a vital part of our diverse economy, and this will help level the playing field for Missouri manufacturers.” Effective August 28, 2007, Senate Bill 30 exempts from state tax (4.225 percent) and local use tax, but not local sales tax: (note the exemption is for local use tax but not local sales tax)
- Electrical energy
- gas, whether natural, artificial, or propane
- water
- coal
- energy sources
- chemicals
- machinery equipment
- materials
All of the above may be exempt if they are:
- used or consumed in the manufacturing, processing, compounding, mining, or producing of any product; or
- used or consumed in the processing of recovered materials; or
- used or consumed in research and development related to manufacturing, processing, compounding, mining, or producing any product.
Examples of Activities That Are Not "Manufacturing, Processing, Compounding,
Mining, or Producing a Product:"
A. Preparing a meal in a restaurant.
B. Constructing a road, building, or other fixed structure.
C. Florist activities.
Examples of Activities That Are "Manufacturing, Processing, Compounding,
Mining, or Producing a Product:"
A. Making cabinets and countertops.
B. Making modular homes.
C. Making pre-fabricated steel or concrete products.
D. Preparing framed photographs or pictures.
E. Testing of manufacturing equipment before it is installed.
F. Commercial printing.
G. Producing a wireless or landline based telephone call.
H. Bakeries.
AOL Wins in District Court in Iowa
Iowa seems to be in the sales tax news a lot lately. Their amnesty offer just expired, they issued the landmark ruling thwarting pumkin buyers and now they lose this case to AOL.
This case (America Online, LLC v. Iowa Department of Revenue, Iowa District Court for Polk County, No. CV 6482, September 18, 2007) is interesting because of the arguments AOL used. Basically, it went like this: IA taxes intrastate telecom which is when the call originates and terminates in IA. AOL subscribers are given a local IA telephone number to dial to hook up to the Internet. IA argued that was intrastate telecom. Seems like a pretty decent argument.
AOL succeeded in arguing that while the users called a local number, they were actually calling into servers in VA that authenticated them and got them hooked up. There would be no Internet access without the VA servers.
The District Court agreed with them. No word if Iowa is going to appeal it. We can get you a copy of the case if you'd like it.
This case (America Online, LLC v. Iowa Department of Revenue, Iowa District Court for Polk County, No. CV 6482, September 18, 2007) is interesting because of the arguments AOL used. Basically, it went like this: IA taxes intrastate telecom which is when the call originates and terminates in IA. AOL subscribers are given a local IA telephone number to dial to hook up to the Internet. IA argued that was intrastate telecom. Seems like a pretty decent argument.
AOL succeeded in arguing that while the users called a local number, they were actually calling into servers in VA that authenticated them and got them hooked up. There would be no Internet access without the VA servers.
The District Court agreed with them. No word if Iowa is going to appeal it. We can get you a copy of the case if you'd like it.
Thursday, November 1, 2007
The Long Arm of the Cigarette Tax Law in Montana
This Montana cigarette tax case (Vanderbyl v. Department of Revenue, Montana State Tax Appeal Board, No. MT-2007-66, October 15, 2007) is an interesting case because you don't often see a state go after individual purchasers who buy taxable stuff over the Internet. I'm sure that in the not-too-distant future, they will start to do so, because they can mine a lot of information from the Internet itself. There'll be no need to have the SSTP probably. They'll be collecting more tax than ever. Just my humble prediction.
In this case, Tobacco taxes were held to be due on cigarettes purchased from an out-of-state distributor and shipped to taxpayers residing in Montana. The taxpayers argued that the distributor used deceptive business practices by not providing information regarding the taxpayers' responsibility to pay state tobacco taxes. They also claimed that a portion of the cigarettes were purchased by friends and family to save on shipping. However, the taxpayers were ultimately responsible for paying the tax, regardless of whether the distributor used deceptive business practices. Also, the taxpayers failed to provide any information related to purchases made by friends and family, so the taxpayers were deemed the ultimate consumers of the cigarettes. (summary by CCH)
In this case, Tobacco taxes were held to be due on cigarettes purchased from an out-of-state distributor and shipped to taxpayers residing in Montana. The taxpayers argued that the distributor used deceptive business practices by not providing information regarding the taxpayers' responsibility to pay state tobacco taxes. They also claimed that a portion of the cigarettes were purchased by friends and family to save on shipping. However, the taxpayers were ultimately responsible for paying the tax, regardless of whether the distributor used deceptive business practices. Also, the taxpayers failed to provide any information related to purchases made by friends and family, so the taxpayers were deemed the ultimate consumers of the cigarettes. (summary by CCH)
Internet Access Ban In Effect 7 More Years -- What About VOIP?
A couple of items caught my eye in this bill that was signed to extend the moratorium on taxing Internet access. One has to do with sales taxes and the other with state income taxes.
Here's one provision that impacts sales taxes:
"Internet access" does not include voice, audio or video programming, or other products and services using Internet protocol for which there is a charge, regardless of whether the charge is bundled with charges for "Internet access."
In other words, it looks like video downloading services,VOIP, etc. would not be federally defined as "Internet Access". So it would then be open season by the states on these services.
We have a copy of the actual law, we can .pdf to you if you would like it. Just ask.
Here's one provision that impacts sales taxes:
"Internet access" does not include voice, audio or video programming, or other products and services using Internet protocol for which there is a charge, regardless of whether the charge is bundled with charges for "Internet access."
In other words, it looks like video downloading services,VOIP, etc. would not be federally defined as "Internet Access". So it would then be open season by the states on these services.
We have a copy of the actual law, we can .pdf to you if you would like it. Just ask.
Caveat Pumpkin Vendors -- IA Knows What You Did Last Halloween
File this in your "someone in Iowa has too much time on their hands" folder. According to the Iowa Tax e-News, issued by the IA DOR, as quoted in the CCH's State Tax Review, of October 12, 2007, only certain kinds of pumpkins can be purchased tax exempt in IA.
This type of thing is always great news for grocery stores. Get this: Pumpkins are only exempt if: (1) the buyer completes a sales tax exemption certificate stating they will be using the pumkin as food. Oh, my, so stores will have to maintain copies of these certificates too.
But wait! There's more. The store can't just take the certificate and go on, they have to verify that the particular pumpkin purchased is a specific variety that would normally be used for pumpkin pies.
There is one safe-harbor though. If the pumpkins are purchased with food stamps they are exempt.
This type of thing is always great news for grocery stores. Get this: Pumpkins are only exempt if: (1) the buyer completes a sales tax exemption certificate stating they will be using the pumkin as food. Oh, my, so stores will have to maintain copies of these certificates too.
But wait! There's more. The store can't just take the certificate and go on, they have to verify that the particular pumpkin purchased is a specific variety that would normally be used for pumpkin pies.
There is one safe-harbor though. If the pumpkins are purchased with food stamps they are exempt.
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