Fredonia Products Co. v. Procaccino

The sole issue presented by this proceeding is whether purchases by petitioner between September 1, 1969 and August 31, 1972 of sheet pulp, also known as filter paper, used by petitioner in the processing of grape juice, were exempted from the tax on retail sales (Tax Law, § 1105) and the compensating use tax (Tax Law, § 1110). Section 1115 (subd [a], par [12]) of the Tax Law, as in effect at the times in in question (L 1965, ch 94, § 1), exempted from such taxes the receipts from the sales of the following:

"Machinery or equipment for use or consumption directly and exclusively in the…