Ezel / Tax Rulings / CA

Were installed concrete cattle feed and water troughs materials, and was installation labor taxable?

Short answer The trough units were materials creating real-property improvements, and receipts for installing them were excluded from the tax measure.
State
CA
Ruling
Annotation 190.0320
Tax type
Sales and Use Tax
Issued
1964-09-29
Issued by
California State Board of Equalization
Requested by
R--- C--- Company
Topics
feed troughs materials real property improvements installation labor
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1964. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1964
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 September 29, 1964 Associate Tax Counsel letter reports an approved preliminary-hearing conclusion for the taxpayer's concrete cattle feed and watering trough units. It gives limited installation facts but classifies the units as materials improving realty and removes installation-labor receipts from the measure. Modern agricultural structures require their own attachment, fabrication, and contract analysis.
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

Concrete cattle feed troughs and watering troughs were materials that became improvements to realty when the taxpayer installed them.

The approved recommendation excluded receipts for installation labor from the tax measure and called for redetermination on that basis.

Common questions

Were the troughs fixtures?

No. The letter classified them as materials.

Was installation labor included in the tax measure?

No.

What procedural result was recommended?

A redetermination excluding the installation-labor receipts.

Source

Original ruling text

190.0320

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

September 29, 1964

R--- C--- Company
P. O. Box XXX
--- ---, California
Attention:

F-69808

Mr. D--- F. R---

Gentlemen:
This is with regard to the preliminary hearing regarding the tax treatment of cattle feed trough and watering trough units sold by your firm. We have concluded that the units are materials and result in improvements to realty when installed by your firm. Accordingly, we are recommending that a Redetermination be made which will exclude from the measure of tax receipts representing labor for installing the feed and water troughs. Very truly yours,

Robert H. Anderson
Associate Tax Counsel

RHA:spg
cc:
--- --- – District Administrator
Attached are two copies of the report of hearing officer dated September 16, 1964, which has been approved. This hearing was held in --- --- on September 1, 1964.

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