In a letter ruling, the Tennessee Department of Revenue stated that a business that fabricated iron and steel could accept a resale certificate from a dealer planning to resell the material rather than install it. The fabricator would have to collect tax on sales made to contractors for installation if the sale or the use of the product took place in Tennessee. If the product was shipped outside of Tennessee, tax would not be due unless the contract stated that title passed in Tennessee, the common carrier delivering the goods was also the buyer of the goods or the buyer hired the carrier to pick up the goods in Tennessee. (Letter Ruling No. 04-37, Tennessee Department of Revenue, November 23, 2004)