(1) Is the "true object test a useful mechanism for distinguishing sales of tangible personal property from sales of services or intangibles? Does it have a high predictive value, i.e., would you feel confident in providing advice to a client as to whether a court is likely to find the "true object" of a transaction to be the sale of tangible personal property, or the sale of services or intangibles? If not, why not?

(2) Can the purchase of computer software and digital products be taxable as tangible personal property, intangible property or services? Reference Hellerstein (Computer Software and Digital Products),