17 June 2002 Internal T.I. 2001-0111717 F - BFT ET CONSTRUCTION MAISON EN USINE -- summary under Paragraph (c)

In finding that a fabricator of manufactured homes was engaged in a manufacturing and processing given that the exclusion for “construction” did not apply, the Directorate referred inter alia to its “position that construction activities generally take place on a construction site and that manufacturing activities are generally carried out off a construction site” and noted that “Aco has a lot of factory equipment that a building contractor does not have” and that “[m]ost of its work is done off-site.”