The Department of Taxation and Finance has issued an Advisory Opinion concluding that a company engaged in the business of selling advertising space on fixtures installed at hospitals, such as digital displays, backlit static and scrolling displays, and wraps and banners, need not collect tax on those sales, because the sale of advertising is not an enumerated service under Tax Law § 1105(c). However, sales tax is due on the payments made by the company to an independent contractor for installing and maintaining the displays, as charges for installing or maintaining tangible property, since the advertising displays were not intended to become permanent installations and therefore were not capital improvements. Tax is also due on the amounts the company pays to vendors for components and materials used in the displays. Advisory Opinion, TSB-A-12(20)S (N.Y.S. Dep’t of Taxation & Fin., Aug. 28, 2012).