AT&T Technologies, Inc. v. Limbach

The decision of the BTA is reversed in part and affirmed in part.

*12As to the ASRS, AT&T argues that it is an adjunct to manufacturing, excepted by former R.C. 5739.01(R), and, in the alternative, that it is transportation and handling equipment exempted by former R.C. 5739.02(B)(16).

AT&T’s alternative argument is cogent and persuasive. AT&T contends that the function of the ASRS is to coordinate the delivery of materials to the rest of the production facility and that the primary use of the ASRS is for interplant or intraplant transfers of tangible personal property in the process of production…