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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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440.0000 Property Used in Manufacturing—Regulation 1525

Annotation 440.1893

(b) Property Becoming Component Part of Finished Product

(1) In General

440.1893 Medical Products—Commercial Fermentation Process. Cell growth and product expression occur in large vessels in the production of certain protein medical products. Growth of the cell population to production scale is facilitated by maintaining the cells in a fluid which mimics the serum environment. Maintenance and growth of the population require the addition to the vessel of nutrients, growth factors, antibiotics, products that protect the cells from mechanical damage during mixing, and other properties. Any product introduced into the mix which becomes, or a fraction of which becomes, a component of the ultimate protein product can be traced at the atomic level.

Properties which physically contribute to the end product which is sold may be purchased for resale. Products which are introduced into the vessels and contribute to the success of the fermentation process which are not resold may not be purchased for resale. The cells themselves may not be purchased for resale. 5/3/88.