McCORMAC, J.
Jemo Associates, Inc., has appealed a decision of the Board of Tax Appeals affirming the Tax Commissioner's determination that Jemo was liable for sales tax on its purchase and use of property consumed in building a project called Fairlawn Apartments. Jemo is a contractor that was successful in bidding for the construction of a multiple unit apartment project for low income elderly residents in Archbold, Ohio. Jemo was provided with an exemption certificate...
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