- Stingray Pressure Pumping provides fracking services for oil and gas extraction.
- Ohio exempts some equipment from sales and use tax for oil and gas production.
- Stingray challenged the Ohio Board of Tax Appeals’ decision that some of their equipment did not qualify for the exemption.
- The Court of Appeals determined that the statute applied retroactively, and the case was remanded for consideration under the new statute.
- The Supreme Court analyzed the items listed in the new statute to determine applicability of the exemption.
- The Court concluded that all items, except the data van, qualified for the exemption.
- The Court also concluded that certain services were exempt without having to qualify as being “used directly in the production of crude oil and natural gas for sale.”
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