J.C. Penney Co. v. Limbach

Appellant argues that the charges in question were for installation labor and not fabrication labor and that the record does not support the BTA’s conclusion that fabrication occurred at the site. It contends that the invoices pertained only to labor charges, that the appellee, Tax Commissioner, made no mention of separating tangible personal property from labor in her order, and that she had determined that the questioned charges were for fabrication labor and, thus, taxable as part of the “price.”

In Southwestern Portland Cement Co. v. Lindley (1981), 67 Ohio St. 2d 417, 21 O.O. 3d 261, 424…