Consolidation Coal Co. v. Kosydar

The issue for determination here is whether the items described above are used or consumed “* * * directly in the production of tangible personal property for sale by * * * mining * * R. C. 5739.01(E) (2).

This “direct use” exception has been the subject of a number of cases before this court. The test used is found in Youngstown Bldg. Material & Fuel Co. v. Bowers (1958), 167 Ohio St. 363, 367:

“In attempting to interpret the ambiguous word, ‘directly,’ as used by the General Assembly, this court has adopted a physical test: When does the manufacturing or processing activity begin and end, and…