The New York Division of Tax Appeals found that packaging materials used in the distribution of sample drugs by a pharmaceutical manufacturer were exempt from tax. This is in contrast to the Division of Taxation’s argument that the packaging was not transferred to a “purchaser” and therefore did not qualify for the exemption granted to packaging material. Rather, the Division of Tax Appeals found that a purchaser who is expressly exempt from tax on the sale of packaging material likewise is exempt from tax on the use of such material, regardless of who is using the material. (Pharmacia & Upjohn Co., New York Division of Tax Appeals, Tax Appeals Tribunal, DTA No. 818583, July 22, 2004.)