Charter Communications Entertainment I, LLC Missouri Cases

The Director of Revenue appealed a decision by the Administrative Hearing Commission (AHC) which found Charter Communications Entertainment I, LLC (CCE I) was entitled to manufacturing exemptions for use tax paid on replacement equipment. The Director argued that CCE I's provision of telecommunications services does not qualify as manufacturing and that the equipment was not "used directly" in manufacturing. The Missouri Supreme Court affirmed the AHC's decision, holding that telecommunications services constitute manufacturing for tax exemption purposes and that a "substantial use" requirement is not engrafted onto the "used directly" in manufacturing exemption.