Dow Chemical Co. v. Department of Revenue

The plaintiff, The Dow Chemical Company, is engaged in the business of furnishing what are called “stimulation treatments” for oil and gas wells, and sometimes for water wells. In the course of these treatments, chemicals are injected into the well, and the operator of the well is billed separately for them. Upon the ground that the chemicals thus used were sold at retail by the plaintiff, the Department of Revenue levied deficiency assessments against it under the Retailers’ Occupation Tax Act (Ill. Rev. Stat. 1959, chap. 120, pars. 440-453) in the sum of $66,932.43. The assessments covered…