Recently, the Indiana Department of Revenue determined that a taxpayer’s testing and recertification activities did not qualify for a manufacturing exemption. The taxpayer, who tests and recertifies used gas cylinders for its customers pursuant to federal regulatory requirements, contended that it was a remanufacturer of used gas cylinders and therefore was entitled to a manufacturing exemption. Upon arrival of the cylinders, the taxpayer performs a visual inspection and the cylinders that pass inspection are recertified. The Department concluded that although this recertification process is complex, it does not substantially change the existing cylinders. In addition to this, the work performed on the cylinders was contemplated as a normal part of the life cycle of the existing cylinders. As a result the taxpayer was found not to be a remanufacturer of used gas cylinders and therefore, not entitled to any manufacturing exemptions. (Letter of Findings, Indiana Department of Revenue, September 30, 2009)