Pledger v. Noritsu America Corp.

David Newbern, Justice.

The Appellee, Noritsu America Corporation (Noritsu), sells automated equipment, or “minilabs,” purchased and used by businesses which process film. The Department of Finance and Administration (DF&A) assessed a use tax against Noritsu for its 1983 through 1988 Arkansas sales. The tax was paid under protest. The assessment was upheld in an administrative proceeding, and Noritsu sued to recover the tax and interest paid. The Chancellor agreed with Noritsu’s contention that the equipment falls within the manufacturing exemption from use tax found in Ark. Code Ann. §…