In this case, the taxpayer is a retail home improvement company whose primary customers are “do-it-yourselfers.” The equipment under debate was used to cut and size products in the manner requested by customers. Contrary to the Divisions of Taxation’s argument that the materials had left the production line as they entered into the retail distribution chain in marketable form, the Court held that the production process did not end until the product was finished and packaged for sale. The materials sold by the taxpayer were identified as “not usable without being cut.” Therefore, it was determined that the retailer’s “cutting machines were used directly in the production of tangible personal property for sale by the retailer.” (Lowe’s Home Center, Inc v New York Division of Tax Appeals, Administrative Law Judge Unit, DTA No 819043, March 11, 2004)