Allen V. Smith, Inc. v. Bowers

The question presented by this appeal is a narrow one and is based on an uncomplicated factual situation. Unfortunately, its resolution is not correspondingly simple.

The difficulties which the Tax Commissioner, the Board of Tax Appeals and this court, to say nothing of the taxpayers themselves, have experienced in determining the question with which we are faced arise from the language of the statute itself, Avhich provides in part:

‘ ‘ A person who purchases, receives or holds personal property for the purpose of adding to its value by manufacturing, refining, rectifying, or combining…