Commonwealth v. Olan Mills, Inc. of Ohio

Opinion by

Judge Menceb,

This tax appeal presents the Court with yet another factual situation to be evaluated in order to determine what is “manufacturing” within the meaning of the Tax Act of 1963 for Education1 which exempts manufacturing activities from taxation. The two issues raised in this appeal are whether the use of cameras and films in connection with the making of custom-made portraits is included in the phrase “manufacture of personal property” as defined in the Act, and, if so, whether the manufacturing exclusion applies where the production of the portrait is actually done…