MOYER, C.J.
The issue presented by this appeal is whether the sale of an intraocular lens by a manufacturer to an ophthalmologist for subsequent implantation in the eye of a patient is a "retail sale" subject to the excise taxes imposed by R.C. 5739.02 and 5741.02. We conclude that this transaction is not a "retail sale" pursuant to the provisions of R.C. 5739.01(E)(1), and reverse the decision of the Board of Tax Appeals.
R.C. 5739.01(E)(1) states:
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