7-Eleven, Inc. v. Combs
7-Eleven, Inc. sued the Comptroller of Public Accounts and the Attorney General of Texas seeking a partial refund of sales tax on financial software. The trial court granted summary judgment to the State, which 7-Eleven appealed. 7-Eleven argued its software transfers to out-of-state franchisees qualified for a sale-for-resale exemption and that software for out-of-state company stores was not subject to Texas use tax. The appellate court reversed the summary judgment for the State and remanded the case, highlighting the applicability of the sale-for-resale exemption to the franchise software and the materiality of the 'use' definition for out-of-state company stores, requiring further factual development.