In Re Michelin North America, Inc.

HUNTER, JR., ROBERT N., Judge.

*482 Michelin North America, Inc. ("Michelin") appeals from a Final Decision of the North Carolina Property Tax Commission determining certain airplane tires held in Michelin's Mecklenburg facility are subject to taxation. Michelin contends the tires are statutorily excluded from *483 taxation as "inventories owned by manufacturers." We agree and therefore reverse the decision of the Property Tax Commission.

I. Factual and Procedural Background

On 4 November 2011, Michelin appealed the assessed value and penalty of the business's personal property assessed during a…