A Virginia taxpayer disputed its classification on an audit as a real property contractor and maintained that it is a retailer of countertops, regardless of whether or not it installs the countertops. According to the Virginia Tax Commissioner, the countertop sold and installed by the taxpayer became real property upon installation, and therefore, the taxpayer was correctly classified as a real property contractor. Its sales and installations of granite and marble countertops were subject to retail sales and use tax. Furthermore, the Commissioner ruled that that the machinery, tools, and supplies used to fabricate the countertops were also subject to tax. Generally, tools and supplies used to install tangible personal property are taxable at the time of purchase, whether the installed property remains tangible or becomes real property after installation. (Ruling of Commissioner, P.D. 10-20, Virginia Department of Taxation, March 26, 2010)