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BTLG Table of Contents > Sales and Use Tax Annotations > C > 190.0000 Construction Contractors > Annotation 190.2690

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C

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190.0000 Construction Contractors—Regulation 1521

Annotation 190.2690

(d) Fixtures and Materials Purchased for Out-of-State Use

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190.2690 Modular Homes for Export. A taxpayer manufactures modular homes from used cargo containers which are purchased in California. The houses are shipped overseas where they are installed onto real property by the taxpayer. The taxpayer wishes to avoid tax by qualifying under section 6067 which exempts from tax sale of construction materials and fixtures to persons holding seller's permits and who use the property in the performance of a contract to improve realty outside the state. The taxpayer may not obtain a seller's permit solely for the purpose of qualifying for the exemption. A seller's permit can only be issued to a person who is in the business of selling tangible personal property in California. 11/4/94.