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Although the tax law does exempt essential materials used during the actual manufacturing of the product sold , certain items are specifically excluded from that exemption . The judge reminded the parties that because the taxpayer was not trying to prove that it fell within an exemption provided by the law ( instead the burden was on the Tax Division to prove that the work in question was a taxable service ) , any doubts must be resolved in favor of the taxpayer . The company asked about its tax responsibilities when installing the liner in a new pipeline . We added subsections ( a ) ( 5 ) ( E ) and ( F ) to reflect changes in the tax law , effective October 1 , 1995 , defining as " non-commercial use " ( and therefore not taxable ) the off - wing processing , overhauling or repairing of a jet turbine engine or its parts for a certificated or licensed carrier of persons or property , and the repair , maintenance or restoration of rolling stock . The outer zones of these star systems are analogous to the region around Saturn 's orbit and beyond in our own solar system .