Indiana Department of Revenue v. Interstate Warehousing, Inc.

ON PETITION FOR REVIEW

SULLIVAN, Justice.

Interstate Warehousing, Inc., uses electricity to liquify ammonia that is then used to chill warehouse space that Interstate rents to customers to store perishables. Interstate seeks to avoid the taxes due on its electricity purchases. We find that Interstate does not qualify for the statutory tax exemption it seeks because Interstate's use of the ammonia does not constitute the "production of other tangible personal property" and because Interstate is not in the "business of ... processing."

Background

Interstate Warehousing, Inc. ("Interstate"), is an…