Was a leased pickup-and-camper combination registered as a house car mobile transportation equipment?

Plain-English summary

California considered a leased combination pickup and camper registered with the DMV as a house car.

The memorandum said the lease was not a lease of mobile transportation equipment under section 6023. Effective January 1, 1972, Vehicle Code section 465 included a house car within the passenger-vehicle definition, placing the registered combination outside MTE treatment.

The source did not discuss tax calculation or reporting beyond that classification.

Source limits and later agency position

The January 19 memorandum says only that it followed a January 14 telephone conversation. No call notes, written request, registration certificate, vehicle specifications, lease, parties, amounts, use evidence, return, assessment, payment, or other transaction record appears in the official PDF. The source therefore establishes its classification answer but not the underlying facts or any final tax amount.

The live 335.0070 annotation materially tracks the memorandum's single holding. Neither source supplies an exception, alternative classification, or result for a pickup-camper that was not registered as a house car.

A later official May 28, 1975 memorandum for Annotation 335.0014 states that the Board could not rely on DMV classifications and would apply tax according to a vehicle's actual MTE status regardless of the DMV label. That later source does not erase the published 1972 memorandum, but it prevents treating house-car registration alone as a universal current classification rule.

Common questions

Was the pickup-camper combination MTE?

No, when registered as a house car under the rule described in the memorandum.

What legal classification controlled the result?

The source relied on the inclusion of house cars within the Vehicle Code's passenger-vehicle definition.

Did the memorandum examine the vehicle or decide a tax amount?

No. The official source preserves only the classification response following a telephone conversation; the registration, vehicle, lease, and tax records are absent.

Citations and references

• California Revenue and Taxation Code section 6023
• California Vehicle Code section 465
• January 14, 1972 telephone conversation with Marysville district staff — referenced but not documented
• CDTFA Annotation 335.0014 (May 28, 1975) — later agency position that DMV classifications could not be relied on

Verbatim support

From the official January 19, 1972 memorandum:

Since a house car is included within the definition of a passenger vehicle under Section 465 of the Vehicle Code, a lease of a combination pickup and camper which is registered as a house car with the Department of Motor Vehicles will not be regarded as mobile transportation equipment within the meaning of Section 6023 effective January 1, 1972.

Source

• Annotated Legal Opinions collection: https://cdtfa.ca.gov/taxes-and-fees/annotations-menu.htm
• Annotation page: https://cdtfa.ca.gov/lawguides/vol2/suta/335-0000-all.html
• Original supporting opinion: https://cdtfa.ca.gov/lawguides/annotations/335-0070.pdf

Original ruling text

State of California

Board of Equalization

Memorandum

To:

Marysville – Dist. Admin. (COE)

From:

Tax Counsel (GLR) – Headquarters

Subject:

Mobile Transportation Equipment

335.0070

Date:

January 19, 1972

This is in regard to our telephone conversation of January 14, 1972. Since a house car is included within the definition of a passenger vehicle under Section 465 of the Vehicle Code, a lease of a combination pickup and camper which is registered as a house car with the Department of Motor Vehicles will not be regarded as mobile transportation equipment within the meaning of Section 6023 effective January 1, 1972.

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