General Motors Corp. v. Limbach

We will address each of the contested purchases seriatim.

I

Designs and Drawings

GM contracted with several outside design firms to design machinery. The design firms customarily sent the designs on tracings to GM. GM usually sent the tracings to other firms which produced the machinery that GM used in the production process. The machinery had to conform to the design on the tracing.

In a notice of additional authority and at oral argument, the commissioner conceded that these transactions were exempt professional service transactions under Emery Industries, Inc. v. Limbach (1989), 43 Ohio St. 3d…