disabilities. Sanders Brine Shrimp v. Audit Div., 846 P.2d 1304, 1306 (Utah 1993). Thus, where the statute allows an exemption for a sale to the state, a rule enacted pursuant to statute cannot confer a broader exemption. See Utah Concrete Prods. Corp. v. State Tax Comm’n, 101 Utah 513, 125 P.2d 408 (1942). The correct interpretation of rule 42S acknowledges that the first sentence requires a sale to the state or its political subdivisions. Accordingly, RME’s transaction does not qualify under the exemption. RME’s sale of slag was clearly to L.A. Young. It did not negotiate with UDOT nor was it a party to the contract between L.A. Young and UDOT. Thus, because RME did not make a sale to the state, the sale of slag to L.A. Young is a taxable transaction. See id. at 519,125 P.2d at 411 (<HOLDING>). PENALTY In addition to the delinquent tax,
holding that conditional sales of patented devices are not per se illegal but remanding to the district court to determine if the sales at issue were actually conditional holding that sales made to contractor who builds roads for the state are not sales to the state and therefore are not exempt holding that the fact that defendants sales in forum were less than 5 percent of its total sales volume was irrelevant so long as its sales were part of a regular course of dealing and were not isolated or exceptional events holding opinion testimony of sales should have been excluded because opinion not based on comparable sales holding that exercising general jurisdiction over defendant was improper where its actual sales in florida were a small percentage of the total sales and therefore these sales were de minimis 