Ezel / Tax Rulings / CA

Were saw-blade reconditioning charges taxable when customers received similar blades rather than their identical blades?

Short answer Yes. Returning similar blades instead of the customer's originals made the reconditioner's full charge taxable.
State
CA
Ruling
Annotation 315.0760
Tax type
Sales and Use Tax
Issued
1953-04-10
Issued by
California State Board of Equalization
Requested by
A saw-blade reconditioner audited for taxable exchanges
Topics
saw blades reconditioning exchange identical property audit customer property
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 1953 opinion applied historical Ruling 26 and relied on the audit finding that customers did not receive their identical saw blades back. Different tracking, title, pooling, commingling, exchange, or identity facts could change the result. Current saw-blade, repair, reconditioning, exchange, customer-property, and recordkeeping 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 saw-blade reconditioner returned similar reconditioned blades to customers rather than returning the identical blades each customer delivered.

California treated the transaction as taxable under the historical exchange rule. Tax applied to the reconditioner's full charge for the reconditioned property.

Common questions

Did blade identity matter?

Yes.

Was the full charge taxable?

Yes, under the source's exchange treatment.

Would returning the identical blade present the same facts?

No. The opinion was based on returning similar, not identical, blades.

Citations and references

  • Historical Sales and Use Tax Ruling 26

Source

Original ruling text

315.0760

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

April 10, 1953

Dear Mr.
We have received and reviewed the audit report proposing additional sales tax in the amount $64.37 for the period from January 1, 1950, to September 30, 1952. you discussed this audit with me on February 24, 1953, and questioned the application of the tax to your charges for reconditioning saw blades. Accordingly to the audit report, the customer does not receive from you the identical blades that he delivered to you for reconditioning. Accordingly, under the last paragraph of Sales and Use Tax Ruling 26 (copy enclosed) your charges are subject to tax. A notice of a determination will be levied based upon the audit report. You may file a petition for redetermination within thirty days from the date the notice was mailed which would appear on the face of the notice. You may request a hearing before a hearing officer or before the Board.

Yours very truly,

E. H. Stetson
Tax Counsel
EHS:ja
cc:
Stockton - Auditing

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