Ezel / Tax Rulings / CA

Was fabricated Formica material by itself but part of a fixture in a prefabricated cabinet?

Short answer Yes. The described fabricated Formica was material on its own, but when incorporated into a prefabricated cabinet it became a component of the cabinet fixture.
State
CA
Ruling
Annotation 190.1560
Tax type
Sales and Use Tax
Issued
1964-09-18
Issued by
California State Board of Equalization
Requested by
V--- D---
Topics
prefabricated cabinets materials fixtures component
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 18, 1964 Tax Counsel letter is brief and relies on a Formica description contained in the requester's letter, which is not reproduced in the official source. It states only the material classification and the different result when the product becomes part of a prefabricated cabinet fixture. Current laminate and cabinet transactions require fuller factual review.
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

The fabricated Formica described by the requester was material under former Board Ruling 11.

If that Formica became part of a prefabricated cabinet, the completed cabinet was a fixture and all of its components—including the Formica—were part of that fixture.

Common questions

Was fabricated Formica always a fixture?

No. Standing alone, the described product was material.

What changed the classification?

Incorporation into a prefabricated cabinet classified as a fixture.

Citations and references

  • Former California Sales and Use Tax Ruling 11 — meaning of materials and treatment of a prefabricated cabinet as a fixture applied
  • September 14, 1964 requester letter — second-paragraph description of the fabricated Formica identified as the facts answered; not reproduced in the official PDF

Source

Original ruling text

190.1560

STATE OF CALIFORNIA

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

September 18, 1964

Mr. V--- D--Public Accountant - Auditor
XXXX --- Boulevard
--- ---, California XXXXX

Dear Mr. D---:
In answer to your letter of September 14, it is our opinion that the fabricated formica which is described in the second paragraph of your letter constitutes “materials” within the meaning of ruling 11. Should it become part of what under the ruling would be regarded as “prefabricated” cabinet, the cabinet would be a fixture including all of its components including the fabricated formica. Very truly yours,

E. H. Stetson
Tax Counsel

EHS:md
cc:

Hollywood – Subdistrict Administrator

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