Way International v. Limbach

During the audit period, R.C. 5739.02(B)(12)3 provided:

“The [sales] tax does not apply to the following:

*79i(* * *

“(12) Sales of tangible personal property to churches and to organizations not for profit operated exclusively for charitable purposes in this state, no part of the net income of which inures to the benefit of any private shareholder or individual and no substantial part of the activities of which consists of carrying on propaganda or otherwise attempting to influence legislation.

(I * * *

“Nothing in this division shall be deemed to exempt sales to any organization for use in the…