Was undersealing taxable when applied to a customer's used car versus a dealer's car held for sale?

Short answer Used-car undersealing was repair and the applicator consumed the material; dealer undercoating before sale remained part of the taxable car price.
State
CA
Ruling
Annotation 315.0900
Tax type
Sales and Use Tax
Issued
1952-01-08
Issued by
California State Board of Equalization
Requested by
An automotive business buying and applying underseal

Apply this to your situation

This page answers the general question as of 1952. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1952
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 1952 opinion distinguished undersealing a customer's used car from undercoating a dealer's car held for sale. The source treated materials as insignificant in the used-car repair and described a tax-paid-purchases-resold deduction for dealer inventory. Current vehicle, undercoating, repair-material, dealer-inventory, fabrication, and deduction 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

When underseal was applied to a customer's used car, California treated the applicator as the consumer of the material. Tax applied to the applicator's cost of the underseal, not to the charge made to the vehicle owner.

When a dealer undercoated a car held for sale, the full selling price of the car remained taxable without deduction for the labor or materials. The dealer could take a tax-paid-purchases-resold deduction for qualifying tax-paid material applied to the car.

Common questions

Was used-car undersealing taxable to the customer?

No.

Who paid tax on the material?

The applicator, on its purchase cost.

What about a dealer's car held for sale?

Undercoating remained part of the taxable car price.

Citations and references

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

Source

Original ruling text

315.0900

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

January 8, 1952

Mr. J--- D--- P--XXX --- Street
--- ---, California
Attention:

E. E---, Bookkeeper

Dear Mr. P---:
This is in answer to your letter dated December 26, 1951, regarding the tax applicable to the sale of “underseal”. If the work is done on used cars belonging to the customer, the person doing the work is regarded as the consumer of the materials, undersealing in this case, used thereon. Therefore, tax would apply to the cost price of the materials used by the person performing the work. Accordingly, tax is applicable to the sale of “underseal” to you and is not applicable to the charge made your customer for undersealing his automobile. Where a dealer undercoats a car which is to be sold we regard the tax as applicable to the full sales price of the car, without deduction on account of the cost of labor and materials used. In this instance, however, the dealer would be entitled to take a deduction for tax-paid purchases resold in the amount of the cost price of the materials purchased tax paid and applied to the car. Very truly yours,

E. H. Stetson
Tax Counsel

TMH:ja

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