Interlake, Inc. v. Kosydar

The issue in this case is whether the coking equipment is excepted from Ohio sales and use taxes.

*458Appellant contends that the equipment is excepted from the tax by R. C. 5739.01, which reads, in part:

“(E) ‘Retail sale’ * * # include[s] all sales except those in which the purpose of the consumer is:

(C # # #

“(2) * * * to use or consume the thing transferred directly in the production of tangible personal property

for sale by manufacturing, processing * * * .

* #

“ (S) ‘ Manufacturing’ or ‘processing ’ means the transformation or conversion of material or things into a different state or form from…