Ezel / Tax Rulings / CA

Could a leather tanner buy Santotan KR for resale as a component of finished leather?

Short answer Yes. California concluded the basic chrome sulfate was deposited in or chemically combined with the hide to produce finished leather.
State
CA
Ruling
Annotation 260.0080
Tax type
Sales and Use Tax
Issued
1953-06-26
Issued by
California State Board of Equalization
Requested by
W. E. Williams, Board memorandum recipient concerning a redacted tanning company
Topics
leather tanning component resale exemption
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1953. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1953
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 June 26, 1953 internal memorandum classified Santotan KR from its stated identity and role in one-bath chrome tanning. The PDF does not reproduce a request, the cited book's publisher, edition, pages or excerpt, named tanning theories or studies, complete formulation, specifications, chemical analysis, purchase orders, invoices, process records, retention tests, or finished-leather records. CDTFA's current annotation uses malformed anchor id '260-#' but adds no substantive source. The PDF reports no later purchase, formulation or process change, audit, assessment, refund claim, appeal, or other outcome. The memorandum acknowledged no generally accepted chrome-tanning theory but said the hypotheses shared physical deposition or chemical combination. Current product identity, formulation, process, incorporation evidence, transactions, and law control. Another taxpayer should not treat it as binding. 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

California concluded that Santotan KR could be purchased for resale because the basic chrome sulfate became part of finished leather. The source explained that, under the tanning theories it reviewed, a chrome compound was either physically deposited in the hide or chemically combined with its protein matter.

Either mechanism produced the finished leather and supported component treatment.

Common questions

What was Santotan KR?

A basic chrome sulfate used in tanning hides.

Did California require one particular chrome-tanning theory?

No. The memorandum said the leading hypotheses all involved deposition or chemical combination in the hide.

What was the tax result?

Purchase for resale treatment.

Citations and references

  • The Chemistry of Leather Manufacture by McLaughlin and Theis (1945) — cited and characterized without publisher, edition, page, excerpt, or URL
  • Unidentified chrome-tanning hypotheses concerning physical deposition or chemical combination with hide protein — consensus conclusion supplied without named theories, researchers, studies, tests, or citations beyond the cited book in the official PDF
  • Santotan KR identity as basic chrome sulphate and its use in one-bath chrome tanning — facts supplied; complete formulation, specifications, chemical analysis, purchase orders, invoices, process records, mass-balance or retention tests, and finished-leather records not reproduced in the official PDF
  • Official Annotation 260.0080's component, ex-tax, and resale summary and malformed source anchor id 260-# — current annotation supplies no additional product, process, incorporation, transaction, or implementation record
  • Possible later purchase, formulation or tanning-process change, audit, assessment, refund claim, appeal, or other agency action — no follow-up or final outcome supplied in the official PDF

Source

Original ruling text

State of California

Board of Equalization

Memorandum

To:

Mr. W. E. Williams

From:

Bill Holden

Subject:

C--- Tanning Company
--California

260.0080
Sacramento, California
June 26, 1953

Account No. - - XXXX

Santotan KR is a basic chrome sulphate and is purchased for use in the tanning of hides to make leather. “The Chemistry of Leather Manufacture” by McLaughlin and Theis (1945) shows that basic chrome sulphate is used in the one-bath process of chrome tanning. While there is as yet no generally accepted theory of chrome tanning, the various hypotheses all agree that a chrome compound either is physically deposited in the hide or combines chemically with the protein matter in the hide. In any event, the physical or chemical reaction produces the finished leather. It appears therefore that Santotan KR is purchased for the purpose of resale.

Bill Holden

BH:ja

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