In a private letter ruling, the Kansas Department of Revenue stated that the resale of installation services was exempt from tax if the equipment installed is not affixed to real property and the seller had a valid resale certificate. If the labor is applied to real property, the purchaser of the service is deemed to be the consumer. The Department of Revenue also stated that an out of state manufacturer who is registered for sales tax in Kansas and makes a drop shipment to a consumer in Kansas who ordered the product from an out-of-state retailer should collect and remit the compensating use tax if the retailer is not registered to collect it. (Private Letter Ruling No. P-2004-058, Kansas Department of Revenue, December 14, 2004)