Philips Industries, Inc. v. Limbach

The issue presented in this action is whether payment of the annual license tax on aircraft pursuant to R.C. 4561.18 provides an exemption from assessment of the state use tax. Appellant contends that it does. We hold in the negative and accordingly affirm the decision of the Board of Tax Appeals.

The standard of review to be applied to this type of action is well-established. “Statutes relating to the exemption or exception from sales or use taxes are to be strictly construed. * * *” Celina Mut. Ins. Co. v. Bowers (1965), 5 Ohio St. 2d 12, 34 O.O. 2d 7, 213 N.E. 2d 175, paragraph one of the…