In Combs v. Home & Garden Party, Ltd., the taxpayer manufactured certain goods but also resold goods in the same form in which they were purchased. The taxpayer sought a refund under the manufacturing exemption for its purchases of packaging supplies that it used to package both the goods it manufactured and the goods that it resold. Packaging supplies are exempted under the manufacturing exemption when purchased by a manufacturer. The Comptroller’s auditor allowed a refund for only those supplies that were used to package the products manufactured by the taxpayer. The trial court, on motions for summary judgment, found in favor of the taxpayer and awarded a refund for all of its purchases of packaging supplies. The Third Court of Appeals disagreed and held that the manufacturing exemption exempted only those purchases of packaging materials that were used to package items fabricated by the taxpayer.