DeNoon v. Limbach

Moyer, C'.J.

R.C. 5739.01(E)(2) excepts from Ohio sales tax items purchased by a taxpayer that are used or consumed directly in the production of tangible personal property for sale by manufacturing or processing.1 During the relevant audit period, “manufacturing” was defined in R.C. 5739.01(R) (also numbered [S]), in pertinent part, as:

“* * * the transformation or conversion of material or things into a different state or form from that in which they originally existed * * *.”

In Youngstown Bldg. Material & Fuel Co. v. Bowers (1958), 167 Ohio St. 363, 5 O.O. 2d 3, 149 N.E. 2d 1, syllabus, this…