Ezel / Tax Rulings / CA

What portion of a fire-extinguisher recharging charge was subject to California sales tax?

Short answer Only the fair retail value of materials furnished; recharging labor was treated as nontaxable repair or reconditioning.
State
CA
Ruling
Annotation 315.0520
Tax type
Sales and Use Tax
Issued
1954-05-11
Issued by
California State Board of Equalization
Requested by
A business recharging fire extinguishers
Topics
fire extinguisher repairs reconditioning materials fair retail value
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1954. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1954
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 1954 opinion addressed a $1.40 extinguisher-recharging price in which approximately twenty cents represented material cost. It treated the operation as repair or reconditioning and taxed materials at fair retail value. Current extinguisher, recharge, repair, material, labor, invoice, and fair-retail-value 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 fire-extinguisher recharge cost $1.40, with approximately twenty cents representing materials.

California treated the recharge as repair or reconditioning. Sales tax applied to the fair retail value of the materials furnished, but not to the labor portion of the charge.

Common questions

Was the entire recharge price taxable?

No.

What was taxable?

The fair retail value of materials.

Was recharge labor taxable?

No, under the source's treatment.

Citations and references

The supporting opinion does not cite a specific statute or regulation.

Source

Original ruling text

315.0520

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

May 11, 1954

Your letter of April 2
No. 123456

Attention:

x--Secretary-Treasurer

Gentlemen:
You inquire concerning the application of sales tax to the price for recharging fire extinguishers. The price is $1.40 of which approximately 20¢ represents the cost of materials furnished. It is our opinion that this is in the nature of a repair or reconditioning operation and that the tax applies to the price of materials furnished but not to the labor. Accordingly, you should pay sales tax on the fair retail value of the materials furnished.

Yours very truly,

Bill Holden
Assistant Counsel

BH: ja
cc: San Francisco - Auditing

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