A taxpayer who operates a business consisting of three divisions: 1) conveyor sales and services, 2) a machine fabrication shop, and 3) sales of industrial supplies, was not considered to be an industrial manufacturer, and thus, was not eligible for the Virginia sales and use tax manufacturing exemption. Although the taxpayer claimed that each division’s activities should be evaluated separately to determine whether manufacturing activity constituted the majority of its operations, the state disagreed, indicating that they only consider the predominant nature of a business in establishing whether a taxpayer is an industrial manufacturer. The Department’s audit of the taxpayer’s business operations concluded that the primary business activity was conveyor sales and services because 68% of the taxpayer’s sales were attributable to this division. Therefore, the taxpayer’s request for the industrial manufacturing exemption was denied. (Ruling of Commissioner, P.D. 06-09, Virginia Department of Taxation)