BPI's claim for a refund rests upon two sales tax exceptions: the resale exception set forth in R.C. 5739.01(E)(1) and the manufacturing exception contained in (E)(9) of that section. Because we conclude that neither exception applies to BPI's purchase of employment services, we reverse the decision of the BTA.
I
BPI first argues that the purchase of employment services is excepted from sales tax under the resale exception....
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