Madison Seed Co. v. Tax Commissioner

Appellant, Madison Seed Co., Inc., is in the business of marketing seeds to farmers. It obtains raw grains and soybeans from growers under contract, and then prepares them so that they are ready for planting when sold. Appellee, the Tax Commissioner of the state of Ohio, ordered appellant to pay $15,124.53 in sales and use taxes, including a penalty, pursuant to an audit of appellant’s purchases from January 1, 1977 through June 30, 1979. The assessment order was based upon the determination that appellant is not engaged in “manufacturing or processing” within the meaning of R.C. 5739.01(R)…