stating that services cannot be separated from materials when they are necessarily included in the costs of final product or advertising materials constituting tangible personal property, even when billing clearly distinguished between services and goods
How later courts described this case
- stating that services cannot be separated from materials when they are necessarily included in the costs of final product or advertising materials constituting tangible personal property, even when billing clearly distinguished between services and goods
- construing Ark. Code Ann. § 26-53-114 [C] [3] [B]
Written by the judges who cited it.
The opinion
Donald L. Corbin, Justice, dissenting in part. I must respectfully dissent. I would affirm the trial court’s determination that the environmental control system is entitled to a use tax exemption. The sophistication of appellees’ equipment necessitates a controlled environment so as to maintain the computer generated production line. If a computer gets too warm it will not function; and therefore, there would be no production while the production line is down. I fail to see how this system is not directly involved in the manufacturing process.