Polaris Corp. v. Director, Division of Taxation

CRABTREE, J.T.C.

Plaintiff seeks review of a use tax deficiency assessment determined by defendant for the period April 1, 1985 to March 31, 1988 in the amount of $106,952 plus interest and penalty. *72The deficiency pertains to unpaid use tax on materials purchased by plaintiff for use in connection with its roofing business.

Plaintiff is a fabricator/contractor whose business is the on-site fabrication and installation of roofs. It purchases raw materials, specifically, asphalt, mastic, polyester and ceramic surfacing granules from its suppliers. These materials are mixed in specially equipped…