The question before the court in this ease is whether the plaintiff is primarily engaged in manufacturing and assembling goods so as to entitle it to offset personal property taxes against the corporate excise tax, ORS 317.070.①
*123The plaintiff corporation is engaged in the business of selling, installing, manufacturing and assembling various kinds of refrigeration equipment.
The defendant upon the trial conceded that the plaintiff is “primarily” engaged in manufacturing and assembling if “primarily” means “substantially.” It does. This court so decided in Guy F. Atkinson Co. v. Commission, 1 OTR 558 (1964). In this case there is no question but that the plaintiff was “substantially” engaged in manufacturing and assembling during the years in question. From 1958 to and including 1962, from 30 percent to 56 percent of its business came from its manufacturing and assembling activities.
Defendant argues that “primarily” means over 50 percent. If the legislature had so intended it could have used that term or similar words denoting over half. Such words are not complicated or words of art. It did not. It stated that “primarily” engaged was sufficient.
Plaintiff is entitled to the personal property tax offset for the years 1958 to and including 1962. Costs to plaintiff.