A Virginia residential building contractor is liable for the applicable use tax on its purchases of floating floors it purchased; not the subcontractor it utilized to install the flooring. Virginia law imposes tax upon purchases made by real estate construction contractors, not subcontractors. In addition, although the seller is legally obligated to collect the tax from the purchaser, Virginia courts have held the tax is the legal debt of the purchaser (Ruling of Commissioner, P.D. 09-154, Virginia Department of Taxation, October 16, 2009).