In Re Tax Appeal of Alsop Sand Co., Inc.

The opinion of the court was delivered by

Allegrucci, J.:

Taxpayer Alsop Sand Company, Inc., (Alsop) appealed the Kansas Department of Revenue’s (KDR) assessment of additional sales and use taxes on parts of machinery and equipment. Alsop contended that the items were exempt from taxation as “major components” of manufacturing machinery and equip ment under K.S.A. 79-3606(kk). The hearing officer disagreed. Alsop appealed to the Board of Tax Appeals (BOTA), which concluded that the items were exempt. KDR appealed to the Court of Appeals, which concluded that the items were not exempt. 24 Kan.…