How did California classify the components of integrated truck-scale systems?

Plain-English summary

The lump-sum project was a construction contract for an integrated truck-scale system.

Load-cell columns bolted to concrete foundations and scale-platform sections welded to the columns and to one another were materials consumed by the contractor. The reinforcing bars and poured concrete formed part of that installed scale structure.

The six computer-controlled weightmaster consoles and the minicomputer were fixtures because they were accessories to the scales and part of the integrated operation. Communications cables interconnecting the scales, consoles, and computer were materials.

Common questions

How were the scale platforms and load-cell columns classified?

As materials.

How were the consoles and minicomputer classified?

As fixtures integrated with the scales.

How were the connecting cables classified?

As materials.

Citations and references

• Former California Sales and Use Tax Ruling 11 — construction-contractor materials and fixtures framework applied
• February 29, 197X request letter and March 6, 197X telephone conversation — truck-scale system and installation sequence described; not reproduced in the official PDF
• Lump-sum contract with O---, Inc. — four scales, six consoles, a minicomputer, and communications links described; not reproduced in the official PDF

Source

• Annotated Legal Opinions collection: https://cdtfa.ca.gov/taxes-and-fees/annotations-menu.htm
• Annotation page: https://cdtfa.ca.gov/lawguides/vol2/suta/190-0000-all.html
• Original supporting opinion: https://cdtfa.ca.gov/lawguides/annotations/190-1410.pdf

Original ruling text

190.1410

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION
1020 N STREET, SACRAMENTO, CALIFORNIA
(P.O. BOX 942879, SACRAMENTO, CALIFORNIA 94279-0001)
(916) 445-5550

March 7, 1972

Mr. S--- -. W--Assistant Secretary
C--- R--- P--Company
P. O. Box XXXX Terminal Annex
--- ---, CA XXXXX

SR – XX XXXXXX

Dear Mr. W---:

Your letter of February 29, 197X addressed to Mr. John T. Quick has been referred to us for direct reply to you. You request a ruling with regard to the tax liability under a lump-sum contract, entered into with O---, Inc. Under the contract O--- Inc., is to furnish and install four 190’ trick scales, six computer controlled weightmaster consoles and a mini computer to control the weightmaster consoles with a communications link tying together the scale assemblies, consoles and mini computer. According to our telephone conversation of March 6, 197X, we understand that the scale platforms are delivered to the jobsite in 20’ sections and are installed in place. The 16 load cell columns also are bolted in place on concrete foundations. The platform sections are then welded to the load cell columns and the sections welded together, after which you install reinforcing bars and pour the concrete into the scale platform. Under the above facts, it is our opinion that the contractor installing the load cell columns and the sections of the scale “pan” in place is the consumer of the “materials” under ruling 11. It is our opinion that the computer controlled consoles and the mini computer which are interconnected to the scales by the cable constitute “fixtures” which are an accessory to the

Mr. S--- -. W---

-2-

March 7, 1972
190.1410

scales and part of the integrated operations. The cables interconnecting all units, in our opinion constitute “materials.” Should you have any further questions, feel free to write to us. Very truly yours, Joseph Manarolla Tax Counsel

JM:smb
bc:

Los Angeles Dist. - District Admin.
Downey – Subdist. Admin.

Note: Los Angeles - (JTQ) It is felt that the “refinery rule” should not be extended to apply to this type of installation.