GENERAL MOTORS CORP. v. LIMBACH

No. 87-283.

37 Ohio St. 3d 271 (1988)

GENERAL MOTORS CORPORATION, CHEVROLET MOTOR DIVISION, APPELLANT, v. LIMBACH, TAX COMMR., APPELLEE.

Supreme Court of Ohio.

Decided July 6, 1988.


Attorney(s) appearing for the Case

Carlile, Patchen, Murphy & Allison and Robert J. Kosydar, for appellant.

Anthony J. Celebrezze, Jr., attorney general, Mark A. Engel and Richard C. Farrin, for appellee.


Per Curiam.

I

Conveying Equipment

Appellant-taxpayer argues that the conveying equipment is part of a system that produces a saleable product. It argues that the equipment is excepted from sales and use taxes under R.C. 5739.01(E)(2) or 5739.02(B)(16).

R.C. 5739.02 taxes all retail sales made in Ohio.1 R.C. 5739.01(E)(2) excepts sales where the consumer's purpose is "* * * to use or consume the thing...

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