On June 17, 2021, the Department assessed the Taxpayer for gross receipts tax for periods from 2011 to 2018. On March 15, 2019, Taxpayer submitted a protest of the assessment to the protest office. The Taxpayer provided employment staffing services and argued that the receipts received from its clients were comprised of receipts that should have been excluded from gross receipts because they were received solely on behalf of another in a disclosed agency capacity. Regulation states that an agency relationship exists if a person has the power to bind a principal in a contract with a third party so that the third party can enforce the contractual obligation against the principal. The Department, however, argued that there was no evidence to establish that a disclosed agency relationship existed. After reviewing the contracts between the Taxpayer and its private sector and public sector clients, the Hearing Officer determined that the Taxpayer had failed to establish the existence of a disclosed agency relationship in which the Taxpayer had actual authority to bind its customers with third parties. Because the receipts could not be excluded, the Hearing Officer ordered the protest denied.