Per Curiam.
The issue presented for review is whether Jeffrey's acquisition of property from its subcontractors is exempt from taxation under R.C. 5739.01(E)(1). The Board of Tax Appeals held that such property is tax exempt. For the reasons set forth below, we affirm.
R.C. 5739.01 states in part as follows:
"(E) `Retail sale' and `sales at retail' include all sales except those in which the purpose of the consumer is:
"(1) To resell...
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