Ezel / Tax Rulings / CA

Was lima bean straw sold to feed a buffalo herd exempt from California sales tax?

Short answer Yes. California treated the buffalo as food animals because the ranch had established regular restaurant outlets for the meat, so their feed was exempt.
State
CA
Ruling
Annotation 110.0560
Tax type
Sales and Use Tax
Issued
1955-05-04
Issued by
California State Board of Equalization
Requested by
A seller asking whether lima bean straw sold as feed to a buffalo ranch was taxable
Topics
cattle feed food animals exemptions
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1955. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1955
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is a California State Board of Equalization tax-counsel letter dated May 4, 1955, published by CDTFA as support for a sales and use tax annotation. Its conclusion relies on the customer's established specialty-restaurant outlets for buffalo meat and the stated use of lima bean straw as feed. Another taxpayer should not treat it as binding and should check current buffalo, bison, lima-bean-straw, food-animal, feed, meat-market, exemption, and sales-and-use-tax rules. This summary is informational only and is not legal or tax advice.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

Lima bean straw sold to feed a buffalo herd was exempt. The ranch planned to sell buffalo meat to specialty restaurants and had already established regular meat outlets through a similar operation in Kansas, so counsel regarded the buffalo as animals whose products constituted human food.

The ranch also planned to charge the public to drive among the herd, but the feed conclusion rested on the buffalo's established meat market under Ruling 47 as then cited.

Citations and references

  • California State Board of Equalization Ruling 47 (as cited)

Source

Original ruling text

110.0560

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

May 4, 1955

--- --- ----- --- ----- ---, --- XXXXX

Gentlemen:
You inquire concerning the application of tax to your sales of lima bean straw to the operator of a buffalo ranch. The straw is to be fed to the buffalo. The buyer is building a herd of buffalo. Eventually he will have two sources of income from the buffalo. He will charge the general public a fee for the privilege of driving among the herd. He will also sell buffalo meat to specialty restaurants. You state that he has successfully operated a similar enterprise in Kansas and has definitely established regular outlets for the meat. Ruling 47 (copy enclosed) exempts a sale of feed for any form of animal life the products of which ordinarily constitute food for human consumption. It is our opinion that the buffalo raised by your customer should be regarded as animals the products of which constitute food for human consumption. Accordingly, your sales are not subject to tax. Very truly yours,

Bill Holden
Associate Tax Counsel

BH:tj
Enclosure:
cc:

Ruling 47

San Bernardino – Auditing

What does the law say today, for your facts?

This ruling is from 1955. Ezel checks current California tax law against your situation and cites the authority it relies on.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace