This case involves the very situation to which the Government Exemption Provision expressly states the exemption cannot apply. This case involves lump-sum contracts or similar contracts covering both labor and materials for use in the construction of a building. We do not find Appellants' position supported by case law or a plain reading of the provision. We refuse to add language the legislature omitted or overlooked, or to extend the scope of the Government Exemption Provision beyond its plain language. Appellants also argue that the Improvement Provision exempts Appellants from sales and use tax for the purchase of building materials used to construct the Federal Building.
Appellants contend that they individually made the contracted improvements.
Appellants claim that the improvements made in these cases are the same type of improvements made by Appellants to the Federal Building. We do not agree. All the cases cited by Appellants involve the application of the Statute of Limitations under Minn. Stat. The limited analysis offered by these cases regarding improvements is in the context of negligence law and the Statute of Limitations. None of the cases cited involve the application of the Improvement Provision.