Could a color-film laboratory buy the chemical called Dicolamine in the annotation, and Dicolemine in the source letter, for resale?

Plain-English summary

The letter accepted the requester's technical explanation that the chemical used in the Ansco method of color-film processing became incorporated into the finished product.

Because the chemical became part of the product sold, the letter allowed a color-film laboratory to purchase it without tax for resale.

The two official sources spell the chemical differently. CDTFA's live annotation uses "Dicolamine," while the complete supporting letter uses "Dicolemine." The source does not provide enough information to resolve which spelling was intended.

Live annotation and source posture

The current live annotation preserves the incorporation, finished-product, tax-free-for-resale and November 10, 1955 conclusions. It changes both title and body to Dicolamine, while the linked supporting letter prints Dicolemine twice. It also replaces the source's specific Ansco method of color film processing with generic a method of color film processing and omits the missing October 17 explanation and its patent-counsel source.

The supporting PDF supplies no year or copy of the October 17 letter, organization or counsel identity, chemical formula, alternative name, patent, Ansco-process description, scientific source, test, proof of incorporation, purchase, resale certificate, color-film laboratory, finished product, customer sale, invoice, tax filing, audit, assessment, refund or later outcome. It cites no statute, regulation, ruling, case or technical authority. Its two-sentence substance accepts the missing explanation as clear and gives a result; a reader cannot independently evaluate either the spelling or incorporation premise.

CDTFA's Annotated Legal Opinions collection says letters are summarized as annotations and that statutory law controls whenever a statute and annotation conflict. The official one-page PDF has a clean native text layer and one small page-one letterhead stencil rather than scanned text, so no OCR was required. Both fresh direct PDF downloads and both live-page downloads were byte-identical, duplicate default PDF text extractions matched, and the original-text section remains byte-identical to its committed version and the fresh extraction after removal of only the extractor's terminal newline and form feed.

What this means for you

Do not identify a modern chemical or claim component-part treatment from this name alone. Confirm the chemical identity, formula, process, amount remaining in the sold product, purchase and resale records, and current law; the official sources disagree on spelling and provide none of that evidence.

Common questions

Q: Which spelling does the linked letter use?

A: Dicolemine, twice.

Q: Which spelling does the live annotation use?

A: Dicolamine, in both its title and holding.

Q: Did the letter identify the processing method?

A: It named the Ansco method of color-film processing but supplied no description.

Q: What evidence showed incorporation into the finished product?

A: Only a reference to the missing October 17 Patent Counsel explanation, which Counsel called clear.

Citations and references

• October 17 Division Patent Counsel letter — described but absent, with no year printed
• Ansco process, chemical identity, patent, formula, incorporation proof, purchases, sales, tax filings and outcome — implicated but absent
• No statute, regulation, ruling, case or scientific authority — cited in the supporting letter

Verbatim support

From the official November 10, 1955 Associate Tax Counsel letter:

Thank you for your letter of October 17. The explanation was quite clear and we agree that Dicolemine used in the Ansco method of color film processing becomes incorporated into the finished product.

Accordingly, a color film laboratory may purchase Dicolemine tax free for resale.

Source

• Annotated Legal Opinions collection: CDTFA Annotated Legal Opinions
• Live annotation using "Dicolamine": Annotation 420.0520
• Original supporting letter using "Dicolemine": 420.0520 PDF

Original ruling text

420.0520

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION
November 10, 1955

Attention:

X-----------------Division Patent Counsel

Gentlemen:
Thank you for your letter of October 17. The explanation was quite clear and we agree that Dicolemine used in the Ansco method of color film processing becomes incorporated into the finished product. Accordingly, a color film laboratory may purchase Dicolemine tax free for resale. Very truly yours, Bill Holden Associate Tax Counsel BH:tl Cc:

Unit 4 – Headquarters
Los Angeles – Auditing (LJR)