Finally, the Department’s attempt to analogize this case to Mechanics Laundry and Indianapolis Fruit is without merit. In those cases, the taxpayers sought the equipment exemption for equipment used to act upon other goods. In Mechanics Laundry, the taxpayer sought the exemption for equipment used to launder soiled textiles. Mechanics Laundry, 650 N.E.2d at 1227. This Court found that laundering soiled textiles did not produce other tangible personal property. Id. at 1229. “In [Mechanics Laundry], this Court distinguished the production of a marketable good from the perpetuation of a previously manufactured good.” Mid-America, 681 N.E.2d at 263 (citing Mechanics Laundry, 650 N.E.2d at 1230).
In Indianapolis Fruit, the taxpayer sought the exemption for equipment used to ripen bananas and tomatoes. Indianapolis Fruit, 691 N.E.2d at 1382. In that case, the taxpayer actively ripened the bananas by introducing ethylene gas into the banana ripening booth. Id. at 1385-86. The taxpayer allowed the tomatoes to ripen by merely placing them in a tomato processing unit. Id. at 1382. This Court found that the taxpayer was entitled to the equipment exemption for the bananas because the taxpayer had physically and chemically transformed the bananas from unmarketable bananas to marketable ones. Id. at 1381, 1385. The Court, however, found that the taxpayer’s tomato ripening process did not constitute production because the taxpayer did not trigger the ripening process but merely passively allowed it to occur. Id. at 1385-86
Here, the Department incorrectly focuses on whether there is a transformation of the food stored in Interstate’s customers’ refrigerated storage areas. Interstate is not seeking an exemption based upon a claim that the other tangible personal property it