October 27, 1982

You inquire whether sales of ********** ("Reagents") by your company are subject to the Massachusetts sales tax. The Reagents are composed of antibodies derived from animal cells. The animal cells have been immunized by using biological substances obtained from humans. The Reagents are used in research in the detection of human disease. The Reagents are not directly administered to patients.

Massachusetts General Laws Chapter 64H, Section 6(l) exempts from tax sales of medicine on prescriptions of registered physicians and sales of oxygen, blood or blood plasma.

Based on the foregoing, it is ruled that sales of the Reagents to non-exempt customers are subject to the Massachusetts sales tax.

Very truly yours,

/s/L. Joyce Hampers

L. Joyce Hampers
Commissioner of Revenue

LJH:JD:mf
LR 82-98