The Department views the previously described transaction and similar transactions as the rendition of a service in which the service provider consumes tangible personal property. The spreading of the chemicals does not constitute a A sale at retail. The providers consume the chemicals while performing a service. The service provider must pay use tax on chemicals and other materials consumed, unless sales tax was paid at the time these chemicals and materials were acquired. It is immaterial that an employee of the municipality or county road commission may board the vehicle and direct the spreading of the chemicals.
Sales tax is due, unless a valid claim for exemption is obtained from the purchaser.
It does not matter whether the storage tank is stationary or whether it is mounted on a vehicle owned or leased by the purchaser.