McWood Corp. v. Porterfield

The only question before this court is whether the Board of Tax Appeals acted unreasonably and unlawfully in refusing to find the purchases at issue ex-*145eepted- under the provisions of Section 5739.01 (E) (2), Revised Code.

Section 5739.01 (E) (2), Revised Code, provides, among others, the following exception:

“(E) ‘Retail sale’ and ‘sales at retail’ include all sales except those in which the purpose of the consumer is:

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“(2) * * * to use or consume the thing transferred directly in the production of tangible personal property for sale by manufacturing, processing * * * including without…