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HSD, INC. v. IOWA STATE BD. OF TAX REVIEW

No. 98-197.

601 N.W.2d 66 (1999)

HARLAN SPRAGUE DAWLEY, INC., Appellant, v. IOWA STATE BOARD of TAX REVIEW, Appellee.

Supreme Court of Iowa.

October 13, 1999.

Attorney(s) appearing for the Case

B. Keith Shake of Henderson, Daily, Withrow & DeVoe, Indianapolis, Indiana, and James G. Sawtelle and John V. Donnelly of Sullivan & Ward, P.C., Des Moines, for appellant.

Thomas J. Miller, Attorney General, and Harry M. Griger, Special Assistant Attorney General, for appellee.

Considered by McGIVERIN, C.J., and LARSON, NEUMAN, SNELL, and TERNUS, JJ.

LARSON, Justice.

The issue before us is whether raw feed ingredients, pelletized and fed by the plaintiff to its laboratory animals, qualifies under the "processing" exemption from sales tax under Iowa Code section 422.42(3) (1991). We agree with the board of review and the district court that these ingredients are not exempt because the raising of laboratory animals is not "processing" under the statute.

I.

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