Perdue, Inc. v. State Department of Assessments & Taxation

This case adds new monetary dimensions to that timeworn maxim “don’t count your chickens before they hatch” for here the validity of a $183,870.00 tax assessment hinges on the supposition that an egg is an egg and not a chicken. This dispute arose when the State Department of Assessment and Taxation, appellee, levied a tax against Perdue, Inc., appellant, on its average inventory of hatchery eggs during the year 1969. Appellant objected to this levy claiming statutory exemptions because these eggs are “poultry,” and the “raw materials of a manufacturer.” When the tax department made this…