Per Curiam.
Charities asserts that it is exempt from sales and use taxes because it is a charitable organization within the definition of R.C. 5739.02 (B)(12). This section states in pertinent part:
"The tax does not apply to the following:
"* * *
"(12) Sales of tangible personal property or services to churches and to nonprofit organizations operated exclusively for charitable purposes in this state, no part of the net income of which...
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