RIGGS, J.
This case is before the court on direct appeal from a judgment of the Oregon Tax Court. Willamette Egg Farms, Inc. (taxpayer) appeals the denial of a property tax exemption under ORS 307.400(5)(e) (set out below) for tangible property used in its egg-production facility. The Tax Court concluded that equipment used to raise egg-laying chicks to maturity is not "directly related" to the production of eggs. Willamette Egg Farms, Inc. v. Dept. of Rev.,
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