This opinion decides whether the mobile baking pan racks (“Racks”) used by plaintiff in its business of manufacturing baked products are subject to use tax. The amount of tax in dispute is $19,319.65 (exclusive of interest and penalties). Plaintiff claims that the Racks are indispensable to the manufacturing process, and therefore, are exempt under N.J.S.A. 54:32-8.13(a), which statute exempts from tax (sales or use), receipts from sales of “machinery, apparatus, or equipment” (hereinafter “MAE”) which is used or consumed “directly and primarily in the production of tangible personal property by manufacturing, processing, assembling or refining.” Defendant claims that the exemption does not apply to the Racks because they are trolleys akin to dollies, used for the convenience of plaintiff to manually transport the to-be-baked products from one area to another since they are too heavy to be carted or carried by foot.