EICH, J.
The Town of Leeds appeals from a judgment declaring a layer facility owned and operated by Pulsfus Poultry Farms, Inc., to be exempt from property taxation under sec. 70.111(9), Stats. The issue is whether the facility may be considered "farm ... machinery ... actually used ... in farming” within the meaning of the statute. Resolution of the issue necessarily involves interpretation of the "use-function” test as developed in Revenue Dept. v. Greiling, 112 Wis. 2d 602, 334 N.W.2d 118 (1983), and Ladish Malting Co. v. Dept. of Revenue, 98 Wis. 2d 496, 297 N.W.2d 56 (Ct. App. 1980). We conclude that Greiling and Ladish compel the conclusion that the facility comes within the farm machinery exemption and we therefore affirm the judgment.
The facts are not in dispute. As part of its egg-producing activities, Pulsfus maintáins a "layer house” containing approximately 10,800 cages, each cage containing eight hens. It is constructed of steel beam framing and metal siding on a concrete foundation. The lower portion supports the rest of the structure and related equipment, in addition to pro[731]*731viding a facility for the collection of manure. The hen cages are on three decks. They are interconnected and supported by truss rods. Feed troughs run in lines outside the cages, and a conveyor belt system runs underneath to catch the eggs and transport them to a separate packaging facility. The belt system is not mounted to the floor or walls, but is suspended from the ceiling. The main electrical equipment is located outside the house, and the internal electrical system is hung on the side walls.
There are two feed bins outside the structure. They are equipped with an augur-and-chain system which carries the feed inside and moves it down the troughs and past the cages. A series of pipes, attached to the cages by plastic straps, provides water and necessary medication to the hens. The entire system is automated. The farmer-operator uses a system of suspended walkways to enter the structure to observe the hens, repair equipment, etc. The operator spends only a few hours a day on such activities. All in all, the layer house creates a controlled environment for the hens, automatically controlling the temperature, light and humidity twenty-four hours a day. The hens are not aware whether it is light or dark, hot or cold, windy or still. They are fed, watered, medicated and relieved of their eggs and wastes by automated equipment and machinery.
In 1983, the town assessed the house as real property subject to taxation, and Pulsfus commenced this action seeking a declaration that the town’s assessment was unlawful on grounds that the facility was exempt under sec. 70.111(9) Stats. The trial court found in Pulsfus’s favor, and the town appealed. Other facts will be discussed below.
[732]*732Tax exemptions are matters of legislative grace and are strictly construed. Ramrod, Inc. v. Department of Revenue, 64 Wis. 2d 499, 504, 219 N.W.2d 604, 607 (1974). This does not mean, however, that the interpretation of a statutory exemption need be unreasonable or undertaken in the narrowest possible manner. Pabst Brewing Co. v. Milwaukee, 125 Wis. 2d 437, 445, 373 N.W.2d 680, 684 (Ct. App. 1985). "A strict but reasonable construction seems to be the pithy and popular statement of the rule.” Id., quoting Ladish, 98 Wis. 2d at 502, 297 N.W.2d at 58.
The town argues first that the facility is a "building” and thus part of the real estate which cannot be reached by the "farm machinery” exemption — an exemption it contends is limited to personal property. It is true that sec. 70.111, Stats., is entitled "Personal property exempted from taxation,” but Puls-fus correctly points out that section titles are not part of the law. Sec. 990.001(6), Stats; Hoeft v. Milwaukee & Suburban Transport Corp., 42 Wis. 2d 699, 707-08, 168 N.W.2d 134, 138 (1969). While section titles are useful in resolving statutory ambiguities, we do not face that situation here because we believe Greiling and Ladish control our interpretation of sec. 70.111 in this case.1
[733]*733In Greiling, the issue was whether a greenhouse was a "machine used in floriculture thereby qualifying its components for an exemption from the state use tax ...Id., 112 Wis. 2d at 603, 334 N.W.2d at 119. The statute granting the exemption, sec. 77.54(3), Stats., provided that receipts from the sale or use of "machines ... used directly in farming ... or floricul-ture” were exempted from use taxes. The greenhouse at issue consisted of an enclosure constructed out of metal tubing and polyethylene film, with shading, irrigation and ventilation systems designed to provide the optimum environment for plant production. Temperature, humidity, airflow and sunlight were monitored and controlled to permit maximum plant growth.
The Greiling court noted that the term "machine” was not defined in the statute, and adopted the following definition:
(1) "a structure consisting of a framework and various fixed and moving parts, for doing some kind of work.” Webster’s New World Dictionary Second College Edition (1980).
(2) "every mechanical device or combination of devices to perform some function and produce a certain effect or result.” 69 C.J.S. Patents, sec. 10 at 183 (1951).
Greiling, 112 Wis. 2d at 605-06, 334 N.W.2d at 120. The court, noting that the greenhouse did not function simply as a shelter or storage area for plants, but "actively produce[d] the artificial environment necessary to produce plants for commercial use,” stated [734]*734that it thus must be considered a machine within the quoted definitions. Id.
The court adopted the "use-function” test of Ladish. Under that analysis, the central question is "whether the structure is one 'whose utility is principally and primarily a significantly contributive factor in the actual manufacture or production of the product itself.’” Ladish, 98 Wis. 2d at 506, 297 N.W.2d at 60, quoting 5 Mertens, Law of Federal Income Taxation, sec. 32A.14, at 50 (rev. ed. 1980). While Ladish interpreted a statute dealing with tax exemptions for "manufacturing machinery,” rather than "farming” or "floricultural” machinery, the Greiling court saw no reason not to apply the use-function test to the latter class as well. Id., 112 Wis. 2d at 607, 334 N.W.2d at 121. In so doing, the court noted that the greenhouse was designed solely to nurture and produce plants, and could not be viewed as a storage facility because "it has an active function of creating and controlling an environment conducive to the production of floricultural crops ... [and] is a significant contributive factor in the production of plants. On this record, it has no other purpose or function, nor could it be successfully adapted to another use.” Id.
The town and
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EICH, J.
The Town of Leeds appeals from a judgment declaring a layer facility owned and operated by Pulsfus Poultry Farms, Inc., to be exempt from property taxation under sec. 70.111(9), Stats. The issue is whether the facility may be considered "farm ... machinery ... actually used ... in farming” within the meaning of the statute. Resolution of the issue necessarily involves interpretation of the "use-function” test as developed in Revenue Dept. v. Greiling, 112 Wis. 2d 602, 334 N.W.2d 118 (1983), and Ladish Malting Co. v. Dept. of Revenue, 98 Wis. 2d 496, 297 N.W.2d 56 (Ct. App. 1980). We conclude that Greiling and Ladish compel the conclusion that the facility comes within the farm machinery exemption and we therefore affirm the judgment.
The facts are not in dispute. As part of its egg-producing activities, Pulsfus maintáins a "layer house” containing approximately 10,800 cages, each cage containing eight hens. It is constructed of steel beam framing and metal siding on a concrete foundation. The lower portion supports the rest of the structure and related equipment, in addition to pro[731]*731viding a facility for the collection of manure. The hen cages are on three decks. They are interconnected and supported by truss rods. Feed troughs run in lines outside the cages, and a conveyor belt system runs underneath to catch the eggs and transport them to a separate packaging facility. The belt system is not mounted to the floor or walls, but is suspended from the ceiling. The main electrical equipment is located outside the house, and the internal electrical system is hung on the side walls.
There are two feed bins outside the structure. They are equipped with an augur-and-chain system which carries the feed inside and moves it down the troughs and past the cages. A series of pipes, attached to the cages by plastic straps, provides water and necessary medication to the hens. The entire system is automated. The farmer-operator uses a system of suspended walkways to enter the structure to observe the hens, repair equipment, etc. The operator spends only a few hours a day on such activities. All in all, the layer house creates a controlled environment for the hens, automatically controlling the temperature, light and humidity twenty-four hours a day. The hens are not aware whether it is light or dark, hot or cold, windy or still. They are fed, watered, medicated and relieved of their eggs and wastes by automated equipment and machinery.
In 1983, the town assessed the house as real property subject to taxation, and Pulsfus commenced this action seeking a declaration that the town’s assessment was unlawful on grounds that the facility was exempt under sec. 70.111(9) Stats. The trial court found in Pulsfus’s favor, and the town appealed. Other facts will be discussed below.
[732]*732Tax exemptions are matters of legislative grace and are strictly construed. Ramrod, Inc. v. Department of Revenue, 64 Wis. 2d 499, 504, 219 N.W.2d 604, 607 (1974). This does not mean, however, that the interpretation of a statutory exemption need be unreasonable or undertaken in the narrowest possible manner. Pabst Brewing Co. v. Milwaukee, 125 Wis. 2d 437, 445, 373 N.W.2d 680, 684 (Ct. App. 1985). "A strict but reasonable construction seems to be the pithy and popular statement of the rule.” Id., quoting Ladish, 98 Wis. 2d at 502, 297 N.W.2d at 58.
The town argues first that the facility is a "building” and thus part of the real estate which cannot be reached by the "farm machinery” exemption — an exemption it contends is limited to personal property. It is true that sec. 70.111, Stats., is entitled "Personal property exempted from taxation,” but Puls-fus correctly points out that section titles are not part of the law. Sec. 990.001(6), Stats; Hoeft v. Milwaukee & Suburban Transport Corp., 42 Wis. 2d 699, 707-08, 168 N.W.2d 134, 138 (1969). While section titles are useful in resolving statutory ambiguities, we do not face that situation here because we believe Greiling and Ladish control our interpretation of sec. 70.111 in this case.1
[733]*733In Greiling, the issue was whether a greenhouse was a "machine used in floriculture thereby qualifying its components for an exemption from the state use tax ...Id., 112 Wis. 2d at 603, 334 N.W.2d at 119. The statute granting the exemption, sec. 77.54(3), Stats., provided that receipts from the sale or use of "machines ... used directly in farming ... or floricul-ture” were exempted from use taxes. The greenhouse at issue consisted of an enclosure constructed out of metal tubing and polyethylene film, with shading, irrigation and ventilation systems designed to provide the optimum environment for plant production. Temperature, humidity, airflow and sunlight were monitored and controlled to permit maximum plant growth.
The Greiling court noted that the term "machine” was not defined in the statute, and adopted the following definition:
(1) "a structure consisting of a framework and various fixed and moving parts, for doing some kind of work.” Webster’s New World Dictionary Second College Edition (1980).
(2) "every mechanical device or combination of devices to perform some function and produce a certain effect or result.” 69 C.J.S. Patents, sec. 10 at 183 (1951).
Greiling, 112 Wis. 2d at 605-06, 334 N.W.2d at 120. The court, noting that the greenhouse did not function simply as a shelter or storage area for plants, but "actively produce[d] the artificial environment necessary to produce plants for commercial use,” stated [734]*734that it thus must be considered a machine within the quoted definitions. Id.
The court adopted the "use-function” test of Ladish. Under that analysis, the central question is "whether the structure is one 'whose utility is principally and primarily a significantly contributive factor in the actual manufacture or production of the product itself.’” Ladish, 98 Wis. 2d at 506, 297 N.W.2d at 60, quoting 5 Mertens, Law of Federal Income Taxation, sec. 32A.14, at 50 (rev. ed. 1980). While Ladish interpreted a statute dealing with tax exemptions for "manufacturing machinery,” rather than "farming” or "floricultural” machinery, the Greiling court saw no reason not to apply the use-function test to the latter class as well. Id., 112 Wis. 2d at 607, 334 N.W.2d at 121. In so doing, the court noted that the greenhouse was designed solely to nurture and produce plants, and could not be viewed as a storage facility because "it has an active function of creating and controlling an environment conducive to the production of floricultural crops ... [and] is a significant contributive factor in the production of plants. On this record, it has no other purpose or function, nor could it be successfully adapted to another use.” Id.
The town and amicus curiae, the Wisconsin Towns Association, attempt to distinguish Greiling and Ladish on grounds that both cases dealt with the manufacture or production of products, whereas we are dealing here with an agricultural building "used to house and shelter both animals and persons caring for animals.” We disagree.
It is true that Ladish involved the exemption for manufacturing machinery and equipment — the so-called "M & E” exemption. Greiling, however, applied the Ladish usefunction test to the exemption for [735]*735"machines ... used directly in farming ... or floricul-ture,” Greiling, 112 Wis. 2d at 603 n. 1, 334 N.W.2d at 119, an exemption drawn in language substantially identical to the exemption for "machinery ... actually used ... in farming” which is at issue here. The nearly identical language of the two statutes, and the supreme court’s application of the use- function test in Greiling compel the conclusion that it is equally applicable to claims of exemption under sec. 70.111(9), Stats.
We are also satisfied that the trial court correctly applied the test to the Pulsfus layer house. The town argues that the facility does not meet the test because it is designed and employed "to provide shelter and housing for the hens and convenient working space for the operator of the facility.” The town asserts that the facility is simply a replacement for a tradition chicken coop, and thus its utility is not "principally and primarily a significantly contributive factor in the actual manufacture or production of [a] product” within the meaning of the rule. Pabst, 125 Wis. 2d at 445-46, 373 N.W.2d at 685 (citation omitted). The trial court saw it as something different, as do we.
While there was testimony that the facility was designed at least in part for the convenience of the operator’s daily tasks, it has no heat, water or toilets. The floor and lower portion of the structure is a collecting point for manure, and its only provision for human use is the suspended walkway which allows the operator to monitor the hens and maintain the equipment. As indicated, the operator spends only two to three hours a day on these tasks. The entire operation, from the provision and regulation of heat, light and ventilation, to feeding and medicating the [736]*736hens and collecting their eggs and wastes, is automated. The feed bins and feed control scales are located outside the facility, as are the main electric panel and switches for the egg conveyor belt system. The builder of the facility testified that it was designed and constructed for only one purpose, the production of eggs, and he had never known a structure of this type to be converted to any other use. He stated that it would be impractical and economically infeasible to convert the facility into a traditional hen house or chicken coop.
The Pulsfus layer hen facility is little different from the malt house and appurtenant areas in Pabst, and we noted there that "[t]he fact that some human activity, incidental to a structure’s function, is carried on within the structure, does not mean that [it] provides general working space. ... [T]he working space provided in the malt house is merely incidental to its principal function or use.” Id., 125 Wis. 2d at 453, 373 N.W.2d at 688 (citation omitted). More importantly, the layer house is nearly identical to the automated greenhouse in Greiling: "[It] was designed solely to ... produce [eggs]. It cannot be viewed merely as a storage [or shelter] facility because it has an active function of creating and controlling an environment conducive to the production of [eggs]. This [structure] is a significant contributive factor in the production of [eggs]. ... [I]t has no other purpose or function, nor could it be successfully adapted to another use.” Id., 112 Wis. 2d at 607, 334 N.W.2d at 121.
The legislature has seen fit to phrase the "farm machinery” exemption in sec. 70.111(9), Stats, in language nearly identical to the "M & E” exemption in sec. 70.11(27), and the "machine[ry]... used directly [737]*737in farming ... or floriculture” exemption in sec. 77.54(3), Stats. The supreme court has held that the use-function test is the appropriate means of evaluating claims for exemption under the latter two statutes, and we consider that determination to control our interpretation of sec. 70.111(9). We hold, therefore, that the use-function test of Greiling and Ladish is equally applicable to exemptions under sec. 70.111(9), and that the trial court correctly applied that test to the Pulsfus layer house.
By the Court. — Judgment affirmed.