Were charges to grind, sharpen, and rechrome worn cotton-picker spindles taxable fabrication?

Short answer No. The work restored the spindles to approximately their original condition and was treated as nontaxable repair.
State
CA
Ruling
Annotation 315.0460
Tax type
Sales and Use Tax
Issued
1953-07-02
Issued by
California State Board of Equalization
Requested by
A business resharpening and rechroming mechanical cotton-picker spindles

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 brief 1953 opinion applied historical Ruling 26 and depended on grinding, sharpening, and chroming restoring mechanical cotton-picker spindles to approximately their original condition. Different replacements, added components, exchanges, substantial modifications, or new uses could change the result. Current agricultural-equipment, sharpening, plating, repair, and fabrication rules control today.
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

A business ground, sharpened, and rechromed worn mechanical cotton-picker spindles.

California treated the work as nontaxable repair because it restored the spindle to approximately its original condition.

Common questions

Was resharpening taxable fabrication?

No.

Was rechroming taxable in this transaction?

No.

What fact controlled?

Restoration to approximately original condition.

Citations and references

  • Historical Sales and Use Tax Ruling 26

Source

Original ruling text

315.0460

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

July 2, 1953

Attention:

Mr. ---Accountant

Gentlemen:

You inquire concerning the application of sales tax to your charges for resharpening and rechroming mechanical cotton picker spindles. Your work consists of grinding, sharpening, and chroming and results in the restoration of the spindle to approximately its original condition. It is our opinion that this is repair work and is governed by the second paragraph of Sales and Use Tax Ruling 26 (copy enclosed). Accordingly, the sales tax does not apply to your charges for this type of work.

Yours very truly,

Bill Holden
Junior Counsel

BH:ja
cc: Fresno – Auditing

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