372 Mass. 286 | Mass. | 1977
The taxpayer converts natural gas into a liquid through a refrigeration process, and claims that it is a “manufacturing corporation” under G. L. c. 58, § 2,
We summarize the board’s findings. The taxpayer does not own,, buy or sell gas in its natural or liquid form. Its customers deliver gas to it in the warm months, when supplies exceed demand, and it converts the gas into liquid form. The liquid is stored and later, in the cold months of peak demand, is vaporized and distributed. The process of liquefaction is one of refrigeration, compression and removal of certain components of the gas. The processing causes substantial physical and chemical changes in the gas; the purpose is more efficient storage, handling and shipment.
The term “manufacturing” has no technical meaning, and we have used a standard or commonplace definition emphasizing the production of “something possessing a new nature and name and adapted to a new use.” First Data Corp. v. State Tax Comm’n, 371 Mass. 444, 446-447 (1976), quoting from Commissioner of Corps. & Taxation v. Assessors of Boston, 321 Mass. 90, 94 (1947). See the
Decision affirmed.
As amended through St. 1969, c. 537, § 1.
As appearing in St. 1970, c. 634, § 4. See St. 1976, c. 415, § 32.
As appearing in St. 1957, c. 541.