Lyons v. Limbach

R.C. 5739.01(E)(2) provides for exception from the sales tax where the item purchased is used or consumed “* * * directly in the * * * production of crude oil and natural gas, * * * and persons engaged in rendering * * * services in the exploration for, and production of, crude oil and natural gas, for others are deemed engaged directly in * * * exploration for, and production of, crude oil and natural gas * * *.”1

In Kilbarger Constr., Inc. v. Limbach (1988), 37 Ohio St. 3d 234, 525 N.E. 2d 483, we applied the reasoning found in our manufacturing- and mining-exception cases to oil and gas…