Per Curiam.
The issue in this case is whether certain equipment purchased and used by appellant in the production of ferro-alloys is excepted from the Ohio sales and use taxes.
R. C. 5739.01(E)(2) provides, in part:
"(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...
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