General Motors Corp. v. Limbach

I

Conveying Equipment

Appellant-taxpayer argues that the conveying equipment is part of a system that produces a saleable product. It argues that the equipment is excepted from sales and use taxes under R.C. 5739.01(E)(2) or 5739.02(B)(16).

R.C. 5739.02 taxes all retail sales made in Ohio.1 R.C. 5739.01(E)(2) excepts sales where the consumer’s purpose is “* * * to use or consume the thing transferred directly in the production of tangible personal property * * * for sale by manufacturing, [or] processing * *

During the audit period, “manufacturing” or “processing” was defined in R.C. 5739.01(S)…