Federated Department Stores, Inc. v. Kosydar

At issue in this case are two categories of tangible personal property claimed by appellant to be excepted from Ohio sales and use taxes, pursuant to R. C. 5739.01(B) and (E)(2). For purposes of this discussion, the tax in issue will be treated as sales tax, pursuant to R. C. 5741.02(C)(2).

I

The first category of goods assessed by the Tax Commissioner, and at issue herein, consists of advertising materials. These materials consist, in general, of radio and T. V. commercials, and free-lance artists’ sketches used in newspaper and magazine compositions. The assessment *4relating to. radio and T.Y.…