Pratt & Whitney Engine Services v. Dale W. Steager, State Tax Comm.

Justice Ketchum:

In this case we consider whether a large inventory of jet engine repair parts are exempt from ad valorem property taxation. The county assessor, state tax commissioner, and circuit court all considered this question and concluded that the repair parts are not exempt from ad valorem property taxation. After review, we agree with the circuit court’s conclusion and, accordingly, affirm its order.

I. FACTUAL AND PROCEDURAL BACKGROUND

Petitioner Pratt & Whitney Engine Services (“Pratt”) repairs jet engines at its facility in Bridgeport, West Virginia. It maintains a vast inventory of…