Per Curiam.
This appeal presents both a procedural issue and a substantive issue.
R.C. 5739.03(B) provides in part:
"If any sale is claimed to be exempt under * * * section 5739.02 of the Revised Code * * *, the consumer must furnish to the vendor, and the vendor must obtain from the consumer, a certificate specifying the reason that the sale is not legally subject to the tax. * * * If no certificate is furnished or obtained * * * it shall be...
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