Fischer Artificial Ice & Cold Storage Co. v. Iowa State Tax Commission

The question presented to us is whether plaintiff’s purchase and use of electricity for “sharp freezing” and cold storage of meat and other foodstuffs are exempt from Iowa sales and use tax under chapters 422, 423, Code, 1954. Exemp tion is claimed on the ground the electricity was “purchased and used in the processing of tangible personal property intended to be sold ultimately at retail” within the meaning of Code section 422.42(3).

It is not clear whether the tax was assessed under chapter 422 upon the sale of the electricity or under chapter 423 upon its use. Defendant, Iowa State Tax…