A taxpayer’s sales of drawings delivered electronically as PDF files are not subject to New York sales and use tax. The taxpayer sells drawings for patent applications, for courtroom presentations, and for presentation at mediation and arbitrations. When drawings are delivered electronically with no tangible format, the sales of those drawings are not receipts from the sale of corporeal personal property. As a result, the transaction is not a sale of tangible personal property and is not subject to sales and use tax. If however, the drawings are delivered in paper or another tangible medium, they are subject to sales tax as they are considered tangible personal property. (TSB-A-12(23)S, New York Commissioner of Taxation and Finance, September 20, 2012)