CONLEY, J.T.C.
The issue in this case is whether purchases of certain cloth filter pads used by plaintiff in its manufacturing process are exempt from imposition of the New Jersey Sales and Use Tax. Plaintiff has appealed from two separate assessments made by the Director of the Division of Taxation relating to the purchase of the filter pads during the period from January 1, 1973 to June 30, 1979. The assessments total $21,813.49 plus interest and penalties.
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