For the reasons that follow, we affirm the BTA's decision.
KST seeks exemption for these items under R.C. 5739.01(E)(2), which states:
"(E) `Retail sale' and `sales at retail' include all sales except those in which the purpose of the consumer is:
"* * *
"(2) * * * to use or consumer the thing transferred directly in * * * production of crude oil and natural gas * * ...
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