Boswell v. General Oils, Inc.

I must respectfully dissent from the decision of the majority. The premise of the trial court and of the majority decision here is that because an element (sulphur) contained in the oil purchased by Mead Corporation ultimately found its way into the manufactured products (paper and cooking liquor), the purchase of the oil was at wholesale and not subject to sales tax. That premise arises from the decisions of our appellate courts interpreting § 40-23-1 (a)(9)(b), Code of Alabama (1975) and its predecessor Title 51, § 786 (2)(i), Code of Alabama (1940) (Recomp. 1958). Robertson Associates…