The parties stipulate that the question presented is whether plaintiff, a commercial hatchery, is a manufacturing industry or plant within the meaning of G.S. 105-164.4(1) (h).
It is everywhere conceded that the term manufacturing as used in tax statutes is not susceptible of an exact and all-embracing definition, for it has many applications and meanings. Where, as here, the statute does not define the term, courts have resorted to the dictionaries to ascertain its generally accepted meaning and have then undertaken to determine its application to the circumstances of the particular case. There are many holdings and statements to the effect that to constitute manufacturing, the operation, process, or activity in question must produce a new and different commodity or work a *521substantial change in the basic material. See Annot., 17 A.L.R. 3d 7, 23, 27 (1968) ; Duke Power Co. v. Clayton, Comr. of Revenue, 274 N.C. 505, 164 S.E. 2d 289 (1968) ; Bleacheries Co. v. Johnson, Comr. of Revenue, 266 N.C. 692, 147 S.E. 2d 177 (1966) ; State v. Chadbourn, 80 N.C. 479 (1879) ; 55 C.J.S., Manufacturers § 1 (1), (2) (1948).
While the use of sophisticated automated equipment is not determinative of whether a particular operation is manufacturing, many courts have used the fact that such machinery was involved to support their conclusion that the production constituted manufacturing. Annot., 17 A.L.R. 3d 7, 33-34 (1968). See Hearst Corp. (News Amer. Div.) v. State Dept. of A. & T., 269 Md. 625, 639-640, 308 A. 2d 679, 687-688 (1973).
Plaintiff contends that, by means of complicated, precision equipment, it incubates eggs from which are hatched 300,000 chicks a week — production on a scale which could not otherwise be obtained; that by the application of skill and labor to raw material (eggs), a new and more valuable property (chicks) is produced; that the fact plaintiff has duplicated a natural process is immaterial; that this operation constitutes manufacturing within the meaning of the applicable taxing statute as defined by this Court in Duke Power Co. v. Clayton, Comr. of Revenue, supra.
Defendant argues that “since ‘only God can make a tree’ . . . only God can make a baby chick”; that “manufacturing can never occur when the end product is a living organism”; that “the hatchery does not by its skill and labor convert the eggs into baby chicks, because the eggs convert themselves.”
Certainly a commercial hatchery could never produce a chick without the fertilized egg which only a hen and rooster can create. Yet it is equally true that, left alone, an egg could never convert itself into a living organism; it would merely become the odious rotten egg. It is also true that when the setting hen comes off the nest with her small brood, we do not say she has manufactured her chicks. However, her uncomplicated operation in the undisinfected hen house is a far cry from the mass production which the commercial hatchery achieves by the use of modern technology.
Only three decisions on the question here presented have come to our attention. Two support defendant’s contentions: Perdue, Inc. v. State Dept. of Assessment & Taxation, 264 Md. *522228, 286 A. 2d 165 (1972) ; Peterson Produce Co. v. Cheney, 237 Ark. 600, 374 S.W. 2d 809 (1964). As did the Court of Appeals, however, we find convincing the rationale of the third case, Miller v. Peck, 158 Ohio St. 17, 106 N.E. 2d 776 (1952).
In Miller v. Peck, supra, the Supreme Court of Ohio held that the mechanical equipment utilized by a commercial hatchery was used in manufacturing within the meaning of its tax statute which reduced the assessed valuation on “all engines, machinery, tools and implements of a manufacturer.” That court adopted the Century Dictionary’s definition of manufacturing, “the production of articles for use from raw or prepared materials by giving to these materials new forms, qualities, properties or combinations, whether by hand labor or by machinery.” It then inquired, “Does the fact that the process had to do with the mechanical stimulation and development of an animal germ to a living animal itself as the end product for immediate sale in the channels of commerce take the operation out of the category of manufacturing?”
In answering the question NO the court noted: (1) “Usually, where, through the use of tools and machinery commodities or items of personal property are by special treatment or processing transformed into other more valuable items of personal property as a commercial business, the operation is that of manufacturing.” (2) In certain “clearly manufacturing processes” living organisms are used to make new products such as commercial yeast, beer, bread. (To this list we add commercial vaccines.) (3) “The reason for the partial exemption from taxation of tools and machinery used in . . . manufacturing is to encourage such use since it results in the production of more valuable personal property which in turn becomes subject to taxation.” (4) The machinery and equipment of a commercial hatchery are “within the spirit and purpose of the statute” and are therefore entitled to the partial exemption it provides.
In view of the adequate opinion of the Court of Appeals we deem further discussion of the parties’ contentions unnecessary. We hold that plaintiff, a commercial hatchery, is a manufacturing industry within the meaning of G.S. 105-164.4(1) (h). The decision of the Court of Appeals is
Affirmed.