# Bobbie Brooks, Inc. v. Porterfield

> Ohio Supreme Court · November 29, 1972 · 32 Ohio St. 2d 67

URL: https://www.frixlaw.com/law-library/cases/6754983

## Case

- **Full name:** Bobbie Brooks, Inc. v. Porterfield, Tax Commr.
- **Court:** Ohio Supreme Court
- **Decided:** November 29, 1972
- **Citations:** 32 Ohio St. 2d 67; 61 Ohio Op. 2d 305; 289 N.E.2d 899; 1972 Ohio LEXIS 361
- **Precedential status:** Published
- **Opinion:** Opinion of the court
- **Judges:** Brown, Corrigan, Herbert, Leach, Neihl, Schneider, Stern
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/6754983

## Opinion text

Per Curiam.
The issue here is whether the decision of the Board of Tax Appeals is unreasonable or unlawful.
Although the taxpayer claims tax exemption for all purchases, it offered no evidence to show what percentage of the claimed exempted items was used in connection with its cut-and-sew operation at its Cleveland, Ohio, facility, notwithstanding some of the cut-and-sew operations occur in other states, and are performed by both subsidiary corporations and independent contractors. Further, the board noted the failure of taxpayer to establish that it performed “all steps in the transformation of cloth into finished garments.”
The decision of the Board of Tax Appeals is neither unreasonable nor unlawful, and is, therefore, affirmed. Merchants Cold Storage Co. v. Glander (1948), 150 Ohio St. 524 .
Decision affirmed.
O’Neihl, C. J., Schneider, Herbert, Corrigan, Stern, Leach and Brown, JJ., concur.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/6754983. Public record. Not legal advice.