Could domestically produced oil be sold without California sales tax after bonded export storage and withdrawal for vessel or aircraft supplies?
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This page answers the general question as of 1964. Ask about yours and see what current California tax law says, with citations.
Plain-English summary
An unidentified addressee marked only “S” wrote on March 9, 1964 about bonded fuel manufactured in California or elsewhere in the United States. The plan put it in bond in California for ship stores and fuel supplies for certain vessels and aircraft. The request itself is absent.
After unidentified research, tax counsel stated a narrower formulation: domestically produced oil placed in customs-bonded storage for export could be sold without California sales tax when withdrawn for vessel or aircraft delivery as supplies for use in foreign commerce.
The answer supplies no statute, regulation, case or prior ruling. It also does not explain whether “fuel manufactured” and “domestically produced oil” were meant to have exactly the same scope.
No actual sale or evidence that any condition was met appears. The live annotation restates the conclusion but adds no transaction, customs, vessel, aircraft, legal-authority or tax-outcome record.
Common questions
Did California production matter?
The request covered fuel manufactured in California or elsewhere in the United States. The conclusion calls it domestically produced oil, without distinguishing the U.S. production location.
Was ordinary storage enough?
No. The answer required customs-bonded storage for export.
When could the oil leave storage?
It had to be withdrawn for delivery to vessels or aircraft as supplies for use in foreign commerce.
Did counsel identify which vessels or aircraft qualified?
No. The request refers only to “certain” vessels and aircraft, and no route, operator, craft or eligibility rule is supplied.
Which legal authority supported the answer?
None is named. The letter says only that the Board researched the problem.
Was a completed sale or tax result documented?
No. The source supplies no contract, oil, bond, withdrawal, delivery, use, return, audit, assessment or later proceeding.
Citations and references
- March 9, 1964 requester letter — identified, not reproduced
- Unidentified Board research — described without materials or authorities
- Customs-bonded export storage and withdrawal for foreign-commerce supplies — conditions stated without records
- Official Annotation 325.1640 — republishes the conditional conclusion
Source
- Annotated Legal Opinions collection: https://cdtfa.ca.gov/taxes-and-fees/annotations-menu.htm
- Annotation page: Annotation 325.1640
- Original supporting opinion: https://cdtfa.ca.gov/lawguides/annotations/325-1640.pdf
Original ruling text
325.1640
STATE OF CALIFORNIA
STATE BOARD OF EQUALIZATION
May 15, 1964
“S”
This is with reference to your letter of March 9, 1964 concerning the sale of bonded fuel manufactured in California, or elsewhere in the United States, and placed in bond in California for use as ship stores and fuel supplies for certain vessels and aircraft. We have concluded, following research of the problem, that domestically produced oil placed in customs-bonded storage for export, which is withdrawn for delivery to vessels and aircraft as supplies for use in foreign commerce, may be sold for such use without application of the California sales tax. Very truly yours,
E. H. Stetson
Tax Counsel
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