Emerson Electric Co. v. Director of Revenue

RONNIE L. WHITE, Judge.

I. Introduction

Emerson Electric Co. challenged the Director of Revenue’s assessment of use tax paid on machinery used to design, prototype, and test new motors. The Administrative Hearing Commission (AHC) ruled that the assessment was proper and denied Emerson a refund. Emerson seeks review of the AHC’s decision. The parties’ central issue is whether the equipment is “used directly in manufacturing” to qualify for the sales/use tax exemption as contemplated in section Md-OSO^©.1 The Court declines to extend the integrated plant doctrine to these preliminary stages of…