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Arkansas contractor’s entitlement to a sales tax exemption for the construction of a psychiatric residential treatment facility to be used for the care of children and adolescents. Contractors are the end consumers of all materials used in a contract. They pay sales tax on all materials and taxable services used by them in fulfilling the contract. A sales tax exemption is provided for all sales to all orphans’ homes in Arkansas, or children’s homes, which are not operated for profit and whether operated by a church, religious organization, or other benevolent charitable association. The children’s home is operated on a non-profit basis. Consequently, purchases of tangible personal property and services for the children’s home are exempt from Arkansas sales tax. To qualify for an exemption on a purchase made through a purchasing agent, the exempt taxpayer must be the actual purchaser of the materials by contract and in fact. Each exempt purchase and use must be made in the name of, and subject to the approval and control of, the exempt taxpayer. Purchases made by a contractor or subcontractor for use in constructing a building for the requestor will be tax exempt provided those purchases follow certain procedures, which, in the case at hand, are identified in a written agreement...