Ezel / Tax Rulings / CA

Were charges taxable for first-time optical coating and for recoating used glass, plastic, or filters?

Short answer First-time optical coating was taxable, but recoating was not. For mixed new and used filters, tax could be based on the customer's quarterly count of new purchases.
State
CA
Ruling
Annotation 435.1140
Tax type
Sales and Use Tax
Issued
1955-03-24
Issued by
California State Board of Equalization
Requested by
A high-vacuum optical-coating business asking about first-time coating and recoating of glass, plastic, and mixed new and used filters
Topics
filters aluminum new property used property
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1955. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1955
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 associate-tax-counsel letter dated March 24, 1955, published by CDTFA as support for a sales and use tax annotation. It distinguishes first-time coating from recoating and accepts a customer-supplied quarterly count where mixed filters cannot practically be sorted as new or used. Another taxpayer should not treat it as binding and should check current optical-coating, thin-film, repair, recoating, allocation, documentation, 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 high-vacuum coating business evaporated aluminum, fluoride, and other materials onto glass and plastic. The entire charge for coating an item for the first time was taxable, while charges for recoating were not.

One customer sent large batches of filters for fluoride coating, mixing new and repeatedly used filters that could not practically be sorted. The letter did not require piece-by-piece identification.

Instead, the customer could report how many filters it bought each quarter. Tax applied to the coating charge for that number of new filters, and the balance of the batch's coating receipts was treated as exempt recoating.

Citations and references

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

Source

Original ruling text

435.1140

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

March 24, 1955

Mr. G--- B. K--XXXX --- --- Street
--- X, California
Dear Mr. K---:
You are in the business of high-vacuum optical coating. You evaporate aluminum, flouride and other materials on glass and plastics. Tax applies to the entire charge for coating glass for the first time. Tax does not apply to charges for recoating. One of the customers sends in a number of filters to be flourided. Some are new and some are old and it is generally impossible to tell which is which. Large quantities are shipped at a time and it is not feasible for the customer to sort them as they are used over and over. In a case such as this we would not require you to definitely determine whether each filter is new or old. Your customer will be able to tell you how many filters he purchases each quarter. He can thereby determine how many new filters he sends to you for flouriding each quarter. Tax can then be paid on the charge for flouriding this number of pieces and the balance of your receipts from this customer would be regarded as in the exempt category. Very truly yours,

Bill Holden
Associate Tax Counsel

BH: AMN

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