Schulte Oil Co. v. Oklahoma Tax Commission

OPALA, Justice.

Two issues are pressed: [1] Does re manufacture of unusable oilfield pipe constitute “manufacturing” within the meaning of 68 O.S.Supp.1990 § 1352(H) and 68 O.S.Supp. 1988 § 1359(A) and (Q? 1 and if so, [2] Is the diesel fuel used for protestant’s forklifts consumed in the “manufacturing process” and hence exempt from sales tax? 2 We answer both questions in the affirmative.

I

THE ANATOMY OF LITIGATION

RDL Services, Inc. [RDL or taxpayer], appellant, is engaged in the business of (a) converting raw pipe (tubing and easing) into finished oilfield pipe, and (b) refurbishing used and…