Harlan Sprague Dawley, Inc. v. Iowa State Board of Tax Review

LARSON, Justice.

The issue before us is whether raw feed ingredients, pelletized and fed by the plaintiff to its laboratory animals, qualifies under the “processing” exemption from sales tax under Iowa Code section 422.42(3) (1991). We agree with the board of review and the district court that these ingredients are not exempt because the raising of laboratory animals is not “processing” under the statute.

I. Facts and Prior Proceedings.

Harlan Sprague Dawley, Inc. (HSD) manufactures special laboratory animal feed and also raises special strains of “genetically defined” laboratory animals, mainly…