International Research & Development Corp. v. Dept. of Revenue

International Research and Development Corporation, a Michigan corporation, is engaged in the business of testing compounds for its customers, who are manufacturers. The customer furnishes the compounds which International tests in the manner desired by the customer under contract, then submits a report.

During the month of December 1964, and in January and February 1965, International, pursuant to contract, purchased quantities of rats and mice which were used in the process of testing compounds. The purchases were reported to the Department of Revenue as exempt from sales and use taxes by…