State v. Tuscaloosa Cotton Seed Oil Co.

It is a general rule that exemptions from taxation must be strictly construed in favor of the taxing power. Cooley on Taxation (3d Ed.) p. 357. The articles in question were not acquired for prompt shipment, that is, by the appellees as a dealer or broker for immediate resale and shipment, but for the purpose of being manufactured into a compound or mixed commodity of merchandise, but had not been manufactured and were held for the purpose of being converted into manufactured articles. Subdivision (g) of section 2 of tho Revenue Act of 1919, p. 283, exempts the articles there mentioned while…