The Georgia Tax Tribunal held that for sales and use tax purposes contractors are per se consumers of tangible personal property and thus are ineligible for: (1) the sale for resale exclusion, and (2) a regulatory exclusion for property temporarily stored in Georgia while in interstate commerce. The taxpayer is a government contractor that constructs and installs electrical distribution systems at U.S. military airfields in Afghanistan. The taxpayer purchased property out-of-state and temporarily held the property in Georgia prior to shipping it overseas for use in the construction projects. Pursuant to Georgia Regulation 560-12-2-.54, property purchased out-of-state and stored in Georgia is subject to sales and use tax “provided such property has become a part of the mass of the property in [Georgia].” Since the temporarily-stored property had not become part of the mass of property in Georgia, the Tribunal acknowledged that if the regulation controlled, the taxpayer would prevail. But the Georgia Department of Revenue disavowed the regulation, arguing that it was inconsistent with Georgia statutes. Despite the regulation being re-promulgated subsequent to the relevant statutory change, the Tribunal agreed with the Department and declared the regulation to be “at odds with the current statute” and therefore “not controlling.” The Tribunal cautioned that the “case is thus illustrative of the dangers of unthinking reliance on the language of a regulation or undue deference to asserted administrative expertise.” Inglett & Stubbs Int’l, Ltd., v. Riley, No. Tax-IIT-1340253 (Ga. Tax Tribunal Feb. 11, 2015).