Jemo Associates, Inc. v. Lindley

The result reached by the Board of Tax Appeals ignores both the actual certification made and the statutory requirements for certification. The exemption certificate unequivocally certifies that:

“The undersigned hereby certifies that the articles of tangible personal property purchased under this certificate were purchased for incorporation into:

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“A building used exclusively for charitable purposes under a construction contract with a nonprofit organization operated exclusively for the relief of poverty, the improvement of health through the alleviation of illness, disease or injury,…