Southeastern-Kusan, Inc. v. South Carolina Tax Commission

Littlejohn, Justice:

Plaintiff Southeastern-Kusan, Inc. (Southeastern), pursuant to § 12-35-1440, Code of Laws of South Carolina (1976), sees a refund of $67,769.11 sales tax and interest it paid under protest to defendant South Carolina Tax Commission (Tax Commission). The outcome revolves around our interpretation and application of the sales tax exemption in § 12-35-550(17).

' The facts are not disputed. Southeastern manufactures plastic parts and sells them predominantly to. other manufacturers where the parts become integrated into a final product, e. g., plastic components in furniture,…