Custom Beverage Packers, Inc. v. Kosydar

Appellant contends that the pallets are excepted from sales and use taxes by virtue of both R. C. 5739.01(E)(2) and R. C. 5739.02(B) (15).* It contends that the palletizers are excepted from sales and use taxes by virtue of R. C. 5739.02(B) (15) and that the conveyors are excepted from sales and use taxes by virtue of both R. C. 5739.01(E)(2) and R. C. 5739.02(B) (16).

Appellant asserts that these pallets are an integral part of its business. While this may be conceded, it is not *71dispositive of the question of whether the pallets are subject to sales and use taxes.

In the syllabus of Youngstown…