Tax Commission v. J Chas McCullough Seed Co.

OPINION

By ROSS, J.

This is a proceeding in error from the Court of Common ■ Pleas of Hamilton County.

The J. Chas. McCullough Seed Company appealed from a decision of the Tax Commission of Ohio to the Court of Common Pleas, claiming that such corporation was improperly denied by the Commission classification as a manufacturer for the purpose of taxation.

Sec 5385, GC, is as follows:

“A person who purchases, receives or holds personal property, of any description, for the purpose of adding to the value thereof by manufacturing, refining, rectifying, or by the combination of different materials…