American National Can Co. v. Tracy

The seminal question as to the taxability of the machine hoppers turns on whether this equipment constitutes an “adjunct” to direct use during the manufacturing or processing period and therefore is exempt from taxation under R.C. 5739.01(E)(2) and 5739.01(R). In Ball Corp. v. Limbach (1992), 62 Ohio St.3d 474, 478, 584 N.E.2d 679, 682, we quoted Canton Malleable Iron Co. v. Porterfield (1972), 30 Ohio St.2d 163, 170, 59 O.O.2d 178, 181-182, 283 N.E.2d 434, 439:

“ ‘[Manufacturing and processing “ ‘ * * * imply essentially a transformation or conversion of material or things into a different…