Bedford v. Colorado Fuel and Iron

INVOLVED here, upon its petition for a declaratory judgment, is the determination of the tax liability of the Colorado Fuel and Iron Corporation under the Colorado retail sales tax act (S.L. 35, c. 189), and use tax act (S.L. 36, Second Extraordinary Session, c. 11): (1) Upon hundreds of specific items of tangible personal property said to be necessarily purchased and used by it in its manufacturing and mining operations; and, (2) upon hospital and dispensary supplies and equipment purchased and used in conducting its hospital, which it claims is a charitable institution specifically exempt under the provisions of the two statutes. The company, a domestic corporation, is engaged in the manufacture of steel and steel products and the operation of coal mines -- about one-half of its coal production being used in its steel plant located at Pueblo, Colorado -- and in the operation of mines or quarries producing iron, ore, fluor spar, dolomite and limestone, all of which are used in connection with the manufacture of steel at the steel plant.