Per Curiam.
The two issues presented for review are whether the fuel assemblies must be listed under R.C. 5711.22(C) or (D), and whether the commissioner's valuation was reasonable. For the reasons set forth below, we must reverse the decision of the Board of Tax Appeals.
I
R.C. 5711.22, as it applied to tax years 1978-1982, provided:
"(C) Boilers, machinery, equipment, and personal property used for the generation or distribution...
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