In Decor Carpet Mills, Inc. v. Lindley (1980), 64 Ohio St.2d 152, 413 N.E.2d 833, the Ohio Supreme Court determined that state sales taxes, even those wrongfully collected, are a "tax collection for the benefit of Ohio." Id. at 154-55. Furthermore, the Decor court stated that the party collecting the taxes is merely a trustee for the state. Id. Thus, Decor stands for the proposition that any taxes, even those which are overpayments, which are collected on behalf of the state belong to the state as the party collecting the taxes is merely a trustee of those funds. Id.