Ezel / Tax Rulings / CA

Did California treat the 13-by-17-inch fiberboard sheets reviewed in Annotation 195.0400 as taxable purchases?

Short answer No. The memorandum concluded that the sheets were nonreturnable containers and could be purchased without tax.
State
CA
Ruling
Annotation 195.0400
Tax type
Sales and Use Tax
Issued
1950-04-18
Issued by
California State Board of Equalization
Requested by
Internal memorandum to William R. Thomson
Topics
nonreturnable containers ex tax purchase sales tax
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1950. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1950
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 April 18, 1950 internal memorandum states the conclusion for particular 13-by-17-inch fiberboard sheets but does not describe their physical use or transaction facts. The December 15 memorandum and March 22 follow-up it answers are not reproduced in the official PDF. The annotation index supplies additional detail that the supporting memorandum itself does not verify, so this page does not repeat it. Current container and sales-tax rules control.
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

California concluded that the reviewed 13-by-17-inch fiberboard sheets were nonreturnable containers and therefore could be purchased without tax.

The supporting memorandum does not describe how the sheets were used, transferred, or discarded. It records only the conclusion.

Common questions

Does the source explain why the sheets qualified?

No. The complete supporting memorandum does not state the operative use facts.

Citations and references

  • December 15 memorandum — fiberboard-sheet issue referenced; year, author, and separate memorandum not provided in the official PDF
  • March 22 follow-up — same issue referenced; year, author, document form, and separate record not provided in the official PDF

Source

Original ruling text

State of California

Board of Equalization

Memorandum

To:

Mr. Wm. R. Thomson

From:

E. H. Stetson

Subject:

Application of Tax to 13” x 17” Fiberboard Sheets

195.0400

Date:

Sacramento
April 18, 1950

With reference to your memo of December 15 and follow-up of March 22, we have
considered the matter and have concluded that the fiberboard sheets in question are properly
regarded as non-returnable containers and are, therefore, properly purchased ex tax by [A].

EHS:ph

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