Comptroller of the Treasury v. Steuart Investment Co.

RODOWSKY, Judge.

In this retail sales tax case we hold that the respondent’s liquid storage tanks having capacities ranging from 50,000 to 500,000 barrels are to be classified as real property and not as personal property.

Respondent, Steuart Investment Company (Steuart), owns a deep water petroleum terminal covering approximately 300 acres at Piney Point in St. Mary’s County. Standing on the premises are thirty bulk liquid storage tanks. Steuart leases the terminal, including land, pier facilities, bulk storage tanks, buildings and interconnecting pipes to its subsidiary, Steuart Petroleum…