The purchase of machinery and equipment incorporated into Minnesota telecommunications networks was not entitled to the capital equipment exemption from sales and use tax because the equipment was not used to manufacture tangible personal property and because it provides access to communications services. Providing communications services is not deemed to be manufacturing of personal tangible property or to be a taxable service, though the end consumers pay tax on the service they receive. (Sprint Spectrum LP v. Commissioner of Revenue, Minnesota Tax Court, Nos. 7299-R, 7308-R, and 7309-R, May 23, 2003)