BROWN, P. J.
This case is before the court upon appeal from a decision of the Board of Tax Appeals affirming a modified sales and use tax assessment in amount of $4,027.06. The part of the assessment being contested is that relating to two cranes purchased for $64,280 and resulting in a tax of $1,928.40 plus contingent penalties.
These purchases are claimed to be exempt from the tax under Section 5739.01 (E) (2), Revised Code, as sales in which it is "the...
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