April 22, 2026

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Indiana Tax Court
United Parcel Service, Inc. v. Indiana Department of State Revenue
No. 24T-TA-00018

This case addresses whether fuel used by UPS vehicles on private roads is exempt from Indiana’s Special Fuel Tax as fuel used for “nonhighway purposes.” The Indiana Department of State Revenue denied UPS’s refund claims for special fuel tax paid, arguing that fuel consumed on private roads was related to highway operations. The Court found the plain meaning of the statutory language supports that fuel used on private roads falls under the exemption for nonhighway purposes, noting that such usage is distinct from public highway use. Consequently, the Court granted partial summary judgment in favor of UPS, affirming that the fuel consumed on private roads is exempt from the tax. Judge Justin L. McAdam authored the opinion. Petitioners’ attorneys: Maggie L. Smith, Darren A. Craig, FBT Gibbons, Indianapolis, Indiana; and Daniel G. Mudd, FBT Gibbons, Louisville, Kentucky. Respondent’s attorneys: Office of the Indiana Attorney General.

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