Indiana State Board of Tax Commissioners v. Stanadyne, Inc.

While I agree with the majority view that it was error to grant a larger exemption than that properly claimed by Stana-dyne, I feel I must dissent to the grant of the exemption.

The majority acknowledges that exemptions from taxation are not favored and should be strictly construed. Indiana Dept. of State Revenue v. The Boswell Oil Co. (1971), 148 Ind.App. 569, 268 N.E.2d 303.

As I understand the question posed by this litigation, the property was taxable unless imposition of the tax was forbidden by the Commerce Clause of the Constitution of the United States. More precisely, the question is…