Laurel Transportation, Inc. v. Zaino

During August 1991, Laurel Transportation, Inc. (“Laurel”) purchased a 1987 Cessna Citation III (“Citation III”) for $5,300,000 by trading in a Beechcraft King Air and a Cessna Citation II with a combined value of $3,800,000, and by making a cash payment of $1,500,000. The Citation III was purchased out of state and brought into Ohio; however, Laurel paid no use tax, claiming in its unit certificate of exemption that it purchased the Citation III for resale.

Prior to the purchase of the Citation III, Laurel had entered into agreements with Mercury Aviation Company (“Mercury”) and Corporate…