When was a taxidermist's tanning work part of nontaxable mounting rather than taxable hide processing?

Plain-English summary

Counsel reconciled the historical rule taxing hide tanning with the rule treating taxidermists as consumers of materials used in mounting animal skins and heads.

Tanning performed to prepare a skin for mounting was part of the taxidermy service and was not taxable fabrication or processing. That included preparing a bear skin as a rug or wall hanging. Tanning for a different end—such as turning a deer hide into leather—was taxable.

The PDF prints “true limbs,” plaques, wood and iron stands, and hardware as mounting materials consumed by the taxidermist unless the customer was separately charged. The live annotation instead prints “Tree limbs”; the source conflict is not silently resolved.

Source and live-annotation limits

The memorandum does not reproduce the November 21 request, identify a taxidermist or customer, or supply animal skins or heads, tanning and mounting work, purpose evidence, charges, invoices, material purchases, separate-charge records, tax returns, audit, assessment, completed transactions, or later outcome. Former Rulings 10 and 15 are absent. The first paragraph associates taxable hide processing with Ruling 15, while the conclusion attributes other-purpose taxable tanning to Ruling 10; the memorandum does not resolve that inconsistency.

The live annotation preserves the purpose-based tanning distinction and mounting-material consumer rule. It omits the internal auditing request, cited-ruling inconsistency, all-skins-are-tanned premise, separate-charge exception, missing records and authorities, and later-outcome gap. It changes the PDF's printed “true limbs” to “Tree limbs” and dates the opinion December 3, 1958 rather than the source body's December 3, 1956; no separate 1958 source is published.

What this means for you

Taxidermists and tax professionals

Document the customer's requested end product, each tanning and mounting step, whether materials are separately charged, and all material purchases. Check the current rule directly rather than relying on the memorandum's unresolved Ruling 10/15 attribution or the live annotation's unexplained date and wording changes.

Common questions

Was every bear-skin rug charge exempt?

The memorandum treated tanning a bear skin for a mounted rug or wall hanging as part of taxidermy; a different processing purpose could change the result.

How were stands and plaques treated?

They were mounting materials consumed by the taxidermist unless separately charged.

Citations and references

• California Sales Tax Ruling 10 (taxidermists and mounting materials, as cited)
• California Sales Tax Ruling 15 (tanning hides as processing, as cited)
• November 21 request, taxidermy transactions, and cited Rulings 10 and 15 — described or referenced but not included

Verbatim support

From the official December 3, 1956 memorandum:

It is our opinion that the tanning of an animal skin by a taxidermist, for the purpose of preparing it for mounting, does not constitute taxable fabrication or processing under Ruling 10.

However, if the skin is tanned for some purpose other than preparing it for mounting, e.g., converting a deer hide into leather, the charge for such tanning and processing is taxable under Ruling 10.

Source

• Annotated Legal Opinions collection: https://cdtfa.ca.gov/taxes-and-fees/annotations-menu.htm
• Annotation page showing the conflicting 1958 date: https://cdtfa.ca.gov/lawguides/vol2/suta/360-0000-all.html
• Original supporting opinion dated December 3, 1956: https://cdtfa.ca.gov/lawguides/annotations/360-2000.pdf

Original ruling text

360.2000

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

Sacramento
December 3, 1956

To:

Santa Barbara - Auditing (FGP)

From:

Headquarters - Sales Tax Counsel (GAT)

Subject:

Taxidermists

In your letter of November 21, you inquired about application of tax to charges made by taxidermists and the possible inconsistency between Ruling 15, under which tanning of hides constitutes taxable processing; and Ruling 10, under which taxidermists are consumers of materials used in mounting skins and heads. Apparently, all skins are tanned or processed by the taxidermist before they are mounted. It is our opinion that the tanning of an animal skin by a taxidermist, for the purpose of preparing it for mounting, does not constitute taxable fabrication or processing under Ruling 10. This would include the tanning of a bear skin for the purpose of converting it into a rug or wall hanging. However, if the skin is tanned for some purpose other than preparing it for mounting, e.g., converting a deer hide into leather, the charge for such tanning and processing is taxable under Ruling 10. It is also our opinion that true limbs, plaques, wood and iron stands, and hardware used by taxidermists to mount the animals, constitute "materials used in mounting" under Ruling 10, and are consumed by the taxidermist unless he makes a separate charge therefor.

George A. Trigueros
GA T:a'b