American Rock Salt Co. v. Commissioner of Taxation & Finance

*13OPINION OF THE COURT

Lahtinen, J.

Petitioner operates a salt mine in Livingston County under an arrangement with the Livingston County Industrial Development Agency (hereinafter LCIDA). Pursuant to a sales tax exemption letter issued by LCIDA, petitioner leased 600 rail-cars, which were garaged in Livingston County and used exclusively to transport its product from the mine to various locations throughout the United States. The Department of Taxation and Finance determined that petitioner should pay sales and use tax on its acquisition of the railcars.1 Petitioner asserted that, as an agent of…