OAMCO v. Lindley

At issue in this case is whether the various parts of the manufacturing process are directly related to, or used in, the manufacture of appellant’s product. For the reasons which follow, we affirm in part and reverse in part the decision of the Board of Tax Appeals.

Initially, appellant would have this court adopt the integrated plant theory. This theory views all the components of the manufacturing process as a single unit for tax purposes, and would allow no inquiry beyond whether the whole plant was purchased at the same time. It further implies that every component of the plant is directly…