Opinion Number

Dear Mr. Bailey:

You requested the opinion of this office on the following issue:

Whether Company A's inventory purchased out-of-state with a destination of purchase being the business location of Company A is entitled to an exemption for ad valorem taxes based upon La. R.S. 47:1951.3 or Art. VII, Section 21(D) of the Louisiana Constitution of 1974?

You further advised that the inventory is kept at Company A's location until sold to customers, 99% of which are located outside of Louisiana.

The Louisiana Constitution of 1974, Art. VII, Section21(D)(3) provides in pertinent part that,

"Goods,…