An independent franchisee that publishes, prints, and assembles envelopes with advertising coupons and then mails them into North Carolina to potential customers was found liable for use tax on tangible personal property. The taxpayer argues that only non-taxable advertising services are being sold. The distributed envelopes, considered to be the tangible personal property, are free to the public and that they don’t actually “sell” the envelopes. The Secretary ruling, however, states the true object of the transaction is the stuffed envelopes. Without delivery of these there would be no business operations in effect. (Secretary of Revenue Decision No. 2003-442, North Carolina Department of Revenue, March 12, 2004, released May 14, 2004)