Jeep Corp. v. Limbach

R.C. 5739.01(E)(2) excepts from the sales tax purchases in which the purpose of the consumer is “* * * to use or consume the thing transferred directly in the production of tangible personal property * * * for sale by manufacturing [or] processing * * R.C. 5741.02(C)(2) provides the same exemption from the use tax.

The commissioner argues that the BTA did not address the fuel feedback equipment in its decision, and she is unsure that the BTA excepted it. Reading the BTA decision as a whole, we conclude that the BTA did exempt the fuel feedback equipment. Moreover, the commissioner maintains…