Standards Testing Laboratories, Inc. v. Zaino

{¶ 1} Standards Testing Laboratories, Inc. (“STL”) tests tire rims and tires. After a purchase audit by the Tax Commissioner, STL was assessed a use tax on its purchases of tires, wheels (also referred to as rims), lug nuts, and studs for the period April 1, 1991, through December 31, 1994.

{¶ 2} STL filed a petition for reassessment with the Tax Commissioner, contending that it purchased the tires, wheels, lug nuts, and studs for resale in the same form as received and, therefore, the sales should be excepted from taxation as sales for resale. The Tax Commissioner affirmed his assessment,…