RACMP Enterprises, Inc. - Page 23




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          purchases the paper and ink from a manufacturer, the architect's            
          sale of services and materials to his or her clients includes the           
          paper and ink, and the clients purchase the blueprints from the             
          architect.  The essence of the architect's business is providing            
          the service of designing buildings, not the sale of blueprints.             
          Cf. Knight-Ridder Newspapers, Inc. v. United States, 743 F.2d 781           
          (11th Cir. 1984) (paper and ink held by newspaper publisher for             
          use in producing newspapers for sale to customers is inventory).            
               We hold that the inherent nature of petitioner's business is           
          that of a service provider.  Accordingly, we must determine                 
          whether the materials petitioner uses are an indispensable and              
          inseparable part of rendering its services.                                 
               A.  The Liquid Concrete                                                
               Petitioner relies upon our decision in Galedrige Constr.,              
          Inc. v. Commissioner, T.C. Memo. 1997-240, for its argument that            
          the materials are not merchandise.  We agree that the rationale             
          of Galedrige applies to the liquid concrete in this case.                   
               In construing the word "merchandise" in Galedrige, we                  
          applied the rule that "'the natural and ordinary meaning of the             
          words used will be applied * * * unless the Congress has                    
          definitely indicated an intention that they should be otherwise             
          construed'".  Wilkinson-Beane, Inc. v. Commissioner, supra at 354           
          (quoting Huntington Sec. Corp. v. Busey, 112 F.2d 368, 370 (6th             
          Cir. 1940)).  In Galedrige Constr., Inc., for the first time,               






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