Servi-Clean Industries, Inc. v. Collins

The main issue in the instant cause is whether the Board of Tax Appeals’ determination *82that appellant’s supply of clean mops and mats to its customers is not excepted from sales taxes, pursuant to either the R. C. 5739.01(B) exception for personal service or the R. C. 5739.01(E)(4) exception for industrial cleaning or towel and linen service, is reasonable and lawful.

I

Appellant contends that “because the mops and mats are fungible goods,” its transactions “come under the definition of ‘industrial cleaning’ ” and are not subject to tax.

R. C. 5739.01(E) provides, in pertinent part:

“ ‘[Rjetail…