Ruling 89-257, Installation

The sale of furniture is subject to sales and use tax. A separately stated charge on the bill for furniture installation, which includes removing the furniture from its protective carton, arranging the furniture in a particular configuration as well as connecting movable panels and partitions to form office "walls" which are dissembled without damage to the building and not an integral part of the building, is not taxable. However, transportation charges for delivery which occurs prior to the passage of title to the furniture are part of the gross receipts of the tax. Moving the furniture into a building appears to be part of delivery. If delivery and installation charges are commingled, the fee is a part of the measure of the tax for the sale of the furniture.

LEGAL DIVISION

December 7, 1989