Document Number
87-31
Tax Type
Retail Sales and Use Tax
Description
Paper cutting operation; Machinery
Topic
Taxability of Persons and Transactions
Date Issued
02-20-1987
February 20, 1977



Re: Virginia Code §58.1-1821 Application
Retail Sales and Use Tax


Dear ******************

This is in reply to your letter of April 8, 1986 in which you make application for correction of the assessment issued as a result of the department's recent Sales and Use Tax audit of your company, ***************** (Company).
FACTS

Company receives large rolls of paper, which it either cuts down to certain standard sizes, and holds in inventory for resale or cuts into specific sizes upon request by customers. In addition to this paper cutting operation, Company also purchases precut paper for resale without making any modification before the resale of such paper. Additionally, Company uses its machines to cut customer supplied paper to a specific size.

The department assessed Company tax on the purchase of the tangible personal property used in this paper cutting operation. You contend that the purchase of the tangible personal property used in this operation is exempt from the tax under the provisions of Virginia Code §58.1-608.1 (c).
DETERMINATION

Virginia Code §58.1-608.1 (c) exempts from the Virginia Retail sales and Use Tax:
    • machinery or tools or repair parts therefor or replacements thereof, fuel, power, energy, or supplies, used directly in processing, manufacturing, refining, mining or conversion of products for sale or resale;
In making the determination regarding the taxability of tangible personal property under this exemption, the department must look at not only the type of tangible personal property, but the department must also look at the use that is made of such tangible personal property. The same equipment that may be exempt when used by one business is not necessarily exempt when used by another business, or even the same business, if a different use is made of this equipment.

The Virginia Supreme Court, in Golden Skillet Corporation v. Commonwealth, 214 Va. 276, 199 S.E. 2d 511 (1973), held that the above statute was intended "to provide exemption for machinery and tools used in ... manufacturing... products for sale or resale only in the industrial sense," (214 Va. at 278). Therefore, in order for machinery or tools to gain exemption under Virginia Code §58.1-608.1 (c), two tests must be satisfied. First, the machinery or tools must be an integral part of a process in which products are manufactured for sale or resale and second, the manufacturing process must be industrial in nature.

Virginia Code §58.1-602.9 provides in part that:
    • The determination whether any manufacturing, mining, processing, refining or conversion activity is industrial in nature shall be made without regard to plant size, existence or size of finished product inventory, degree of mechanization, amount of capital investment, number of employees or other factors relating principally to the size of the business. Further, "industrial in nature n shall include, but not be limited to, those businesses classified in codes 10 through 14 and 20 through 39 published in the Standard Industrial Classification Manual for 1972 and any supplements issued thereafter.
Based upon the department's review of Company's operations, it does not appear that their operation falls within codes 10 through 14 and 20 through 39 of the Standard Industrial Classification Manual, nor does it appear that their operation is substantially similar to other businesses classified within those codes. Our review indicates that Company is more properly classified under Codes 5111 through 5113, Wholesale Trade Nondurable Goods, Paper and Paper Products. The cutting operation conducted by Company is not an integral part of any manufacturing process. Nor is the Company a manufacturer for purposes of the sales and use tax exemptions.

Based upon the foregoing, I find no basis for correction of the assessment. The full amount of the assessment is hereby due and payable.


Sincerely,


W. H. Forst
Tax Commissioner

Rulings of the Tax Commissioner

Last Updated 08/25/2014 16:46