Hoosier Roll Shop Services, LLC v. Indiana Department of State Revenue, 10 N.E.3d 1051

Hoosier Roll Shop Services, LLC challenged the Indiana Department of State Revenue’s denial of a sales/use tax exemption for equipment used and materials consumed Grinding/calibrating customer work rolls in 2007–2008.
Indiana imposes sales and use taxes; three industrial exemptions allow exemption for property used directly in producing other tangible personal property.
Hoosier Roll argued its grinding/calibration of work rolls creates a remanufactured tool, i.e., other tangible personal property, exempt from tax.
Department contends the process is repair/maintenance of existing rolls, not production of a new good, so no exemption applies.
Court applies Rotation Products four-question framework to decide whether the process produces a new product and qualifies for exemptions.
Court grants Hoosier Roll summary judgment, concluding it produces other tangible personal property.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does grinding and calibrating work rolls produce a new good?	Hoosier Roll creates a remanufactured tool.	Process is repair/maintenance, not production of a new good.	Yes; production of a new good.
Is there added value in the process beyond intrinsic value of new rolls?	Process adds use/value and transforms rolls.	Any value is use value but not market value.	Process adds value to the rolls.
Does remanufactured performance compare to new manufacture?	Remanufactured rolls perform as well as new.	Not disputed; performance likewise.	Remanufactured performance not inferior.
Is grinding/calibration part of normal life-cycle maintenance?	Process not routine maintenance; it transforms into a new tool.	Would be routine maintenance in some contexts.	Not normal lifecycle maintenance; constitutes production of a new product.

Rotation Prods. Corp. v. Dep’t of State Revenue, 690 N.E.2d 795 (Ind. Tax Ct. 1998) (four-question framework to determine remanufacturing vs. repair)