The term "taxable article" or its equivalent are used repeatedly as a term of art throughout the tax code, case law, and Internal Revenue Service guidance to refer to items subject to tax. Did the Sixth Circuit misinterpret "taxable article" in holding that the § 4052(f) safe harbor cannot apply if the sale of the repaired article when new was to a tax-exempt buyer?

Did the Sixth Circuit misinterpret the term 'taxable article' in applying the highway tractor excise tax safe harbor provision when considering sales to tax-exempt buyers?