In a Formal Ruling by the Vermont Department of Taxes, specially designed warehouse racking systems were found to be subject to Vermont sales and use tax. In this circumstance, a racking system was designed and manufactured by an out-of-state company and then installed in a Vermont warehouse by an installation company. The state found that the installer was a contractor making improvements to real property and the installer was subject to use tax on the basis of the materials used to make the racking system. (Vermont Formal Ruling 2007-02, March 5, 2007)