Ag Air, Inc. v. Idaho State Tax Commission

This is an appeal from an order of the district court granting summary judgment in favor of the Idaho State Tax Commission in a case involving an equal protection challenge to section 63-3622D of the Idaho Code which authorizes exemptions to Idaho’s sales and use taxes. We affirm the summary judgment.

I

FACTS AND PROCEDURAL BACKGROUND

A. Facts

Appellant Ag Air, Inc. (Ag .Air) is an Idaho corporation engaged in the business of aerial application of agricultural chemicals. In 1992 and 1994, the respondent Idaho State Tax Commission (Tax Commission) issued three notices of deficiency determina tion…