{¶ 1} Standards Testing Laboratories, Inc. ("STL") tests tire rims and tires. After a purchase audit by the Tax Commissioner, STL was assessed a use tax on its purchases of tires, wheels (also referred to as rims), lug nuts, and studs for the period April 1, 1991, through December 31, 1994.
{¶ 2} STL filed a petition for reassessment with the Tax Commissioner, contending that it purchased the tires, wheels, lug nuts, and...
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