Unitog Rental Services, Inc. v. Director of Revenue

CARL R. GAERTNER, Special Judge.

The sole question presented on appeal is whether equipment used to launder garments is “used in manufacturing”, entitling appellant to an exemption from the sales and use tax.

The facts are undisputed. In 1987, respondent assessed $12,249.56 in Consumer Use Tax against appellant for its in-state use of eight pieces of equipment purchased from out-of-state vendors. The assessments were based on respondent’s position that appellant was not engaged in “manufacturing” for the purposes of § 144-015 and § 144-030.2(4, 5).1 On appeal, the Administrative Hearing…