Sikorsky Aircraft Corporation v. Commissioner of Revenue Services

Summary

The court held that the aircraft manufacturing exemption applies to materials, tools, fuel, machinery, and equipment used in research and development activities indirectly connected to aircraft manufacturing. It also held that the state is not subject to nonmutual collateral estoppel based on an earlier judgment involving different taxpayers. Because the commissioner had conceded that the disputed items qualified for the partial manufacturing exemption, the court affirmed the trial court's judgment granting the full exemption.