NJ USE Tax on MFG Equipment - Preparation of Firewood

[chuck917]

Happy New Year Everyone, from NJ Practitioner!

Question whether the Use Tax exemption under N.J.S.A. 54:32B-8.13(a) / N.J.A.C.18:24-4.4. (Manufactures) applies where a company is preparing Firewood for sale to the public in NJ, where such product is exempt from NJ-ST due to its Energy / Fueling nature.

Only the packaging and delivery costs of Firewood are subject to NJ ST.

My client purchased a significant amount of Equipment for this process and didn't pay ST my concern is whether Use Tax will apply. 

 At the end of the day the State receives no ST on the Equipment purchases nor the sale of finished product to customers,

Any thoughts / direction would be appreciated.

[qbteachmt]

You already asked this, with your research, here:

https://proconnect.intuit.com/community/tax-talk/discussion/nj-use-tax-equipment-used-in-the-mfg-pro...

No need to ask more than once. Thanks.