HERBERT, J.
The principal question in this case is whether the purchases assessed are exempt from sales and use taxation by the state of Ohio under the provisions of Section 5739.02 (B) (14) of the Revised Code.
Section 5739.02 (B) (14) provides, in pertinent part:
"(B) The [sales] tax does not apply to the following:
"* * *
"(14) Building and construction materials sold to construction contractors for incorporation into a structure...
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