Copperweld Steel Co. v. Lindley

The issue presented in this case is whether certain equipment purchased and used by appellant during the audit period in the production of its specialty grade steel alloys is exempt from sales and use taxes.

I

During the period encompassed by the audit, R.C. 5739.01 provided, in pertinent part:

“(E) ‘Retail sale’ and ‘sales at retail’ include all sales except those in which the purpose of the consumer is:

* *

“(2) * * * [T]o use or consume the thing transferred directly in the production of tangible personal property * * * for sale by manufacturing, processing, refining, or mining * *

The terms…