E. Mfg. Corp. v. Testa (Slip Opinion)

*201 {¶ 1} In this direct appeal, we consider whether the Board of Tax Appeals ("BTA") correctly upheld a use-tax assessment on the natural-gas purchases of appellant and cross-appellee, East Manufacturing Corporation ("East"). East contends that the ambient heat provided by the natural gas was necessary for its manufacturing process and that the BTA erred by not granting an exemption under R.C. 5739.011(B)(4), (B)(8), or (C)(5). We disagree and affirm the decision of the BTA.

Relevant Facts and Procedural History

{¶ 2} East manufactures custom aluminum truck trailers. The trailers are fabricated…