Opinion
Theodore L. Sendak, Atty. Gen., Joseph J. Reiswerg, Deputy, for appellants (defendants below).
Charles Schlosser, Jr., Indianapolis, Schlosser, Whites&sSchlosser, Ice, Miller, Donadios&sRyan, Indianapolis, George B. Gavit, G. Daniel Kelley, Jr., Indianapolis, for appellee (plaintiff below).
LYBROOK, Judge.
ON PETITION FOR REHEARING
Our original opinion on the merits of this case appears at 362 N.E.2d 200.
Appellants argue among other matters, in their petition for rehearing, that the farming operations should not have been included in the I.A.A.'s exemption from taxation. Without meeting this issue, we find it necessary to point out that the argument for taxing the farming operation was not seriously presented to either the trial court or this court prior to the petition for rehearing. It is axiomatic that we will not address issues raised for the first time on appeal, much less for the first time on petition for rehearing.
Since the sole issue of our previous decision dealt with the jurisdiction of the trial court, we must leave for another day and another forum, when properly raised, the question of the propriety of exempting the I.A.A.'s farming operation from the Indiana Gross Income Tax.
Rehearing denied.
ROBERTSON, C. J., and LOWDERMILK, J., concur.