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BLUE PRINTING CO. v. BOWERS

No. 34061.

163 Ohio St. 6 (1955)

THE CITY BLUE PRINTING CO., APPELLANT, v. BOWERS, TAX COMMR., APPELLEE.

Supreme Court of Ohio.

Decided March 2, 1955.

Attorney(s) appearing for the Case

Messrs. Thompson, Hine & Flory, Mr. Frank E. Bubna, Mr. William J. Vesely and Messrs. Clark, Hunker, Adelman & Marku, for appellant.

Mr. C. William O'Neill, attorney general, and Mr. Jack H. Bertsch, for appellee.

ZIMMERMAN, J.

Both the Tax Commissioner in making the assessment and the board in affirming the assessment order followed the Tax Commissioner's Rule No 101, which recites in part:

"Charges for making photostats, blue prints * * * do not constitute sales of tangible personal property. Such charges are, therefore, not subject to the tax.

"Where printed pictures are made from developed negatives and sold to...

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