National Church Residences of Chillicothe v. Lindley

The question presented for review is whether the sale of building materials and supplies to appellants for incorporation into their *55respective apartment facilities qualifies for the tax exemption provided under R.C. 57S9.02(B)(12).

R.C. 5739.02, which levies a tax on all retail sales in this state, provides in relevant part:

“(B) The tax does not apply to the following:

n * * *

“(12) Sales of tangible personal property or services to churches and to nonprofit organizations operated exclusively for charitable purposes in this state, no part of the net income of which inures to the benefit of any…