JONES, Justice.
This appeal arises from the action of the Kentucky Department of Revenue which assessed Greene & Webb Lumber Company, Inc., the sum of $5,438.40 in sales and use tax under KRS 139.170. The assessment was based on the lumber company's purchase of certain items of equipment which the Department of Revenue contends do not qualify for exemption as machinery for new and expanded industry under KRS 139.480(8) and KRS 139.170.
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