Pilgrim’s Pride Corp. v. Morris, 723 S.E.2d 642 (W.Va. Sup. Ct. 2011)

(poultry manufacturer that contracts with independent farmers for facilities and labor to raise chickens off manufacturer’s premises does not qualify for exemption from ad valorem taxes under state code because not a “producer” of agricultural products under statute; manufacturer also not qualified for “subsistence of livestock” exemption; statute requires personal property seeking exemption and livestock both be “on hand”, meaning in manufacturer’s physical possession and on the premises; dissent filed, reminding that vertical integration is reality in poultry industry and poultry manufacturer is producer who retains possession of poultry through all phases of production, it should be entitled to both exemptions)

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