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BTLG Table of Contents > Sales and Use Tax Annotations > C > 190.0000 Construction Contractors > Annotation 190.1595

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C

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190.0000 Construction Contractors—Regulation 1521

Annotation 190.1595

(b) Specific Property as "Materials" or "Fixtures"

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190.1595 Framework for Freeway Sign. A taxpayer manufactures a framework to which he attaches a freeway sign supplied by others. The taxpayer then connects the unit, framework and sign, to a freeway bridge by means of anchor bolts already emplaced on the bridge. The metal sign totally covers the framework.

The framework is classified as a fixture rather than materials under Regulation 1521. The framework is not an integral part of the bridge or structure upon attachment. Its function is to support a sign rather than become a structural part of the bridge, its location is upon a structure rather than upon the land itself, it was constructed as a unit and attached as a unit, and upon attachment it did not lose its identity to become an integral and inseparable part of the real property. 1/20/78.