United States Shoe Corp. v. Kosydar

The decision of the Board of Tax Appeals, excepting from taxation the materials incorporated into sample shoes, and the dies, lasts, and other items used to produce those shoes, is neither unreasonable nor unlawful. Taxpayers’ position that their pur*74pose at the time of purchasing the materials was to incorporate them into shoes for sale by manufacturing is uncon-tradicted.

It is true that the initial use of the shoes in question was as sample products. However, at the time of purchase, and at all times thereafter, the taxpayers’ purpose was to incorporate the materials into shoes which were…