Hopkinton LNG Corp. v. State Tax Commission

The taxpayer converts natural gas into a liquid through a refrigeration process, and claims that it is a “manufacturing corporation” under G. L. c. 58, § 2,1 and G. L. c. 63, § 38C.2 It was so classified, but the classification was revoked as of January 1, 1973. The Appellate Tax Board (board) held that the process constitutes a service and not a manufacturing activity, and we affirm. The taxpayer conceded in argument that its alternative claim of exemption under G. L. c. 59, § 5, Sixteenth (2) ,3 for “personal property directly used in the refrigeration of goods,...” is not properly before…