Manufacture includes converting timber into marketable firewood, and tax on the finished product is not barred by earlier taxation of raw material.

Conversion of standing timber into firewood was treated as manufacture because the process created a commercially distinct, marketable article in the course of business. On that basis, the firewood was liable to sales tax as the manufactured product. The objection that taxing timber first and firewood later amounted to double taxation was rejected, because the assessment attached to the transformed commodity rather than to the raw material itself.

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Issues: Whether chopping standing timber into firewood amounted to manufacture so as to render the firewood liable to sales tax, and whether assessment of timber and thereafter of firewood amounted to impermissible double taxation.

Analysis: A manufacturing process was treated as one that brings into existence a commercial article having marketable value in the course of the dealer's business. On that footing, chopping timber into firewood was held to fall within manufacture. Once firewood came into existence as the manufactured commodity, there was no basis to exclude it from assessment merely because the timber had earlier been taxed. The plea of double taxation was rejected on the ground that the assessment related to the transformed commodity.

Conclusion: The chopping of timber into firewood was held to be manufacture, and the resulting firewood was held taxable under the sales tax law. The objection based on double taxation failed.

Ratio Decidendi: Conversion of timber into a commercially distinct and marketable article constitutes manufacture, and taxation of the manufactured product is not barred merely because the raw material had earlier been taxed.

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