O'NEILL, C. J.
The appellant seeks exception from payment of the tax on purchases of bill-changers under the provisions of R. C. 5739.01. The pertinent part of that section reads, as follows:
"(B) `Sale' and `selling' include all transactions by which title or possession, or both, of tangible personal property, is or is to be transferred * * * for a consideration in any manner * * *.
"* * *
"(E) `Retail sale' and `sales at retail' include all...
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