R.W. Sidley, Inc. v. Limbach

For the reasons which follow, we affirm the decision of the Board of Tax Appeals (“BTA”).

Before the BTA, in its notice of appeal and briefs before this court, and in oral argument, Sidley has consistently contested three general categories of items which the commissioner held taxable: items at its precast plant, its silica plant, and its block plant.

I

At the precast plant, Sidley casts and prestresses concrete construction components (e.g., beams and columns) for buildings, parking garages, and bridges. Sidley then assembles or erects the components under construction contracts to furnish…