Rent-A-Center West, Inc. v. Utah State Tax Commission, 367 P.3d 989

Rent-A-Center (RAC) leases consumer goods and offers an optional liability waiver: customers pay an extra fee (7.5% of each rental payment) to avoid reimbursing RAC for loss or damage from enumerated calamities; waiver does not provide repairs or replacement.
Customers sign the waiver with the rental agreement, pay both amounts together, may cancel the waiver anytime, and may purchase early without paying the waiver.
RAC collected sales tax on rental payments but not on the liability waiver fee.
Utah State Tax Commission audited RAC for 2007–2009, assessed tax and interest of ~$147,364 for waiver fees, and upheld the assessment in a formal hearing, reasoning the fee was "paid or charged for" leases under Utah Code §59-12-103(1)(k).
RAC appealed to the Utah Supreme Court. The Court reviews legal questions de novo and framed the issue as whether the liability waiver fee is taxable under the plain statutory text.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the liability waiver fee is an "amount paid or charged for leases or rentals of tangible personal property" under Utah Code §59-12-103(1)(k)	Fee is optional, separately itemized, does not affect possession/use/operation of the rental item, and thus is not "paid for" the lease	Fee is part of the rental transaction (signed with agreement, paid same time, percentage of rent, only available with rental) and therefore taxable as an amount charged for the rental	Reversed: fee is not taxed under §59-12-103(1)(k) because it does not affect possession, use, or operation; it merely waives RAC's claims and is not paid "for" the lease
Whether the Commission's regulation requiring tax on amounts "in connection with" a lease is validly construed to reach the waiver fee	N/A (RAC challenged regulation as inconsistent with statute)	Regulation contends tax applies to all amounts received or charged "in connection with" a lease, encompassing waiver fees	Regulation impermissibly broadens the statute; "in connection with" cannot be read to override the statutory "paid for" requirement and must be construed consistently with the statute

Anadarko Petroleum Corp. v. Utah State Tax Comm’n, 345 P.3d 648 (Utah 2015) (agency conclusions of law reviewed for correctness)
Marion Energy, Inc. v. KFJ Ranch P’ship, 267 P.3d 863 (Utah 2011) (statutory interpretation seeks legislature's intent)
State v. Canton, 308 P.3d 517 (Utah 2013) (use of dictionary for ordinary meaning)
Hi-Country Prop. Rights Grp. v. Emmer, 304 P.3d 851 (Utah 2013) (context/structure inform statutory meaning)
Airport Hilton Ventures, Ltd. v. Utah State Tax Comm’n, 976 P.2d 1197 (Utah 1999) (agency rules invalid if they confer greater disabilities than statute)
Hughes Gen. Contractors, Inc. v. Utah Labor Comm’n, 322 P.3d 712 (Utah 2014) (de novo review of pure legal questions)