KRUPANSKY, J.
The two issues presented in this appeal are as follows: First, whether appellant's transfer of the artwork, color separations and sculptures to outside suppliers constituted a "resale" of those items so as to exempt appellant from sales and use tax pursuant to R.C. 5739.01(E)(1) and 5741.02(C)(2).
Second, whether the Board of Tax Appeals reasonably concluded the evidence was insufficient to establish that certain materials purchased by appellant...
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