Per Curiam.
In case No. 74-938, Emery's argument is premised, first, on the exception from the sales tax found in R. C. 5739.01(E), which, in pertinent part, provides:
"(E) `Retail sale' and `sales at retail' include all sales except those in which the purpose of the consumer is:
"* * *
"(2) To incorporate the thing transferred as a material or a part, into tangible personal property to be produced for sale by manufacturing, assembling...
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