Could crossword puzzle books qualify as exempt periodicals even though they did not convey news?

Short answer Yes, if issued at average intervals no longer than three months. Counsel relied on what the source calls 'letters of general interest.'
State
CA
Ruling
Annotation 385.0200
Tax type
Sales and Use Tax
Issued
1963-08-19
Issued by
California State Board of Equalization
Requested by
San Mateo auditing staff

Apply this to your situation

This page answers the general question as of 1963. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1963
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Disclaimer: This August 19, 1963 California State Board of Equalization Tax Counsel memorandum answers an unpublished August 5 San Mateo audit memorandum. Documents it refers to, such as the request or supporting records, are not published with it. Another publisher should not treat its short conditional answer as binding; current book, puzzle-publication, frequency, periodical, sales-tax, and use-tax law controls. This summary is informational only and is not legal or tax advice.
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

San Mateo audit staff asked in an August 5 memorandum whether crossword puzzle books could be exempt periodicals. The published source does not give that request's year or include it.

California concluded that the books contained what the official memorandum prints as “letters of general interest,” even though they did not convey news. The rendered official page confirms “letters”; this page does not silently change it to “matter” or “material.” Counsel said the books qualified as exempt periodicals if issued at average intervals no longer than three months.

Source and live-annotation limits

The official PDF does not include the August 5 request, crossword puzzle books, contents, titles, publisher, publication dates or schedules, customers, sales, prices, contracts, invoices, returns, audit or assessment, or later outcome. It redacts the account and does not identify a statute or regulation. Regulation 1590 appears in the live collection heading, not the supporting memorandum.

The live annotation repeats only the conditional result that crossword puzzle books issued at average intervals not exceeding three months are exempt periodicals. It omits the August 5 audit request, source's printed “letters of general interest” rationale, absence of news, redacted account, lack of cited authority, and source and outcome limits.

What this means for you

Puzzle publishers and tax professionals

This historical opinion did not require news content, but it made exemption conditional on the source-described general-interest content and stated publication schedule. Preserve consecutive issues and publication records rather than extending the conclusion to different books or frequencies.

Common questions

Q: Did the books convey news?

A: No.

Q: Did that automatically disqualify them?

A: No. Counsel found general-interest content sufficient on the facts described.

Q: What frequency condition applied?

A: Average intervals could not exceed three months.

Citations and references

  • California Sales and Use Tax Regulation 1590 — collection heading only; not cited in the memorandum
  • August 5 San Mateo audit memorandum — described but not included; its year is not printed
  • Books, contents, publication records, transactions, tax records, and outcomes — described or implicated but not documented

Verbatim support

From the official Tax Counsel memorandum:

We believe that such books do contain letters of general interest, although they do not convey "news" as such.

Accordingly, it is our opinion that they qualify as exempt periodicals if issued at average intervals not exceeding three months.

Source

Original ruling text

385.0200

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

August 19, 1963

To:

San Mateo - Auditing (WRP)

From:

Tax Counsel (EHS:PM) - Headquarters
Account -------- -

This is in reply to your memorandum of August 5 requesting an opinion on whether crossword puzzle books qualify as exempt periodicals. We believe that such books do contain letters of general interest, although they do not convey "news" as such. Accordingly, it is our opinion that they qualify as exempt periodicals if issued at average intervals not exceeding three months.

PM: cw

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