Coca-Cola Bottling Co. of Roanoke, Inc. v. County of Botetourt

SENIOR JUSTICE WHITING

delivered the opinion of the Court.

The issue in this appeal is whether personal property was used (1) in a sales business and subject to local taxation, as the trial court held, or (2) in a manufacturing business and a part of the Commonwealth’s tax base as set forth in Code § 58.1-1100, as the taxpayer contends.

Code §58.1-1100 segregates most of the capital of a trade or business as intangible personal property subject to state taxation only. As pertinent here, one class of such intangible personal property is defined in Code § 58.1-1101(A)(2) as “[cjapital which is…