Ezel / Tax Rulings / CA

Was a specialist's separate charge for drilling finger holes in a customer's new bowling ball taxable fabrication labor?

Short answer Yes. Drilling an undrilled new ball to fit the customer's hand was a step in manufacturing the finished article and was taxable fabrication labor.
State
CA
Ruling
Annotation 435.0720
Tax type
Sales and Use Tax
Issued
1977-10-27
Issued by
California State Board of Equalization
Requested by
San Mateo audit staff asking about tax on a specialist's charge for drilling a customer's new bowling ball
Topics
drilling new property fabrication labor
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1977. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1977
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 is a California State Board of Equalization tax-counsel memorandum dated October 27, 1977, published by CDTFA as support for a sales and use tax annotation. It addresses drilling an undrilled new ball after the customer bought it from another retailer and does not decide work on a used ball. Another taxpayer should not treat it as binding and should check current sporting-goods, drilling, new-property, fabrication, and sales-and-use-tax rules. 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

A customer could buy a new bowling ball from one retailer, take delivery without holes, and pay a different specialist to drill finger holes fitted to the customer's hand.

The memorandum concluded that the specialist's separate drilling charge was taxable fabrication labor. Drilling the new ball was a step in manufacturing the finished article rather than repair or other nontaxable labor.

The source addressed only a new, undrilled bowling ball. It did not state a result for redrilling, plugging, or otherwise working on a used ball.

Citations and references

  • No numbered statute or regulation was cited in the source memorandum.

Source

Original ruling text

State of California

Board of Equalization

Memorandum

To:

San Mateo – Auditing (RSG)

From:

Tax Counsel (GJJ) – Headquarters

Subject:

Drilling Holes in Bowling Balls

435.0720

Date:

October 27, 1977

This is in response to your memorandum of October 20, 1977. You have raised a question concerning the applicability of tax to charges made for drilling holes in bowling balls. In the situation in question a customer may purchase a bowling ball from a retailer such as X-------------. The ball sells for $40 and includes drilling holes to fit the customer’s hand. The customer may feel that X--------’s hole drilling is poor so the customer takes delivery of the ball without holes and then takes the undrilled ball to a “quality” driller. The quality driller drills holes in the ball and charges the customer $10. We are of the opinion that the charge made for drilling holes in a new bowling ball constitutes taxable fabrication labor under the Sales and Use Tax Law. Drilling holes in the ball constitutes a step in the manufacturing process of the finished article.

j:alicetilton

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