Ezel / Tax Rulings / CA

Were charges taxable for perforating casing owned by the customer?

Short answer Yes, assuming the customer consumed the casing. Perforating was producing, fabricating, or processing under the cited ruling.
State
CA
Ruling
Annotation 435.1180
Tax type
Sales and Use Tax
Issued
1952-01-24
Issued by
California State Board of Equalization
Requested by
A business asking about charges for perforating casing owned by a consumer
Topics
casing perforating customer furnished property fabrication labor processing
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1952. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1952
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 letter dated January 24, 1952, published by CDTFA as support for a sales and use tax annotation. Its result expressly assumes the customer is the consumer of the casing and does not address resale or repair facts. Another taxpayer should not treat it as binding and should check current casing, perforating, oilfield, fabrication, processing, resale, 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

Perforating customer-owned casing was producing, fabricating, or processing under Ruling 15, as cited.

The charge was taxable on the stated assumption that the customer was the consumer of the casing. The source did not address property processed for resale or repair of used casing.

Citations and references

  • California Sales and Use Tax Ruling 15 (as cited)

Source

Original ruling text

STATE OF CALIFORNIA

435.1180

STATE BOARD OF EQUALIZATION

January 24, 1952

Gentlemen:
This is in answer to your letter dated January 2, 1952, regarding the applicability of the sales tax to the charge for the perforating of casing. In our opinion this operation constitutes a producing, fabricating, or processing within the meaning of Sales and Use Tax Ruling 15, copy enclosed. Accordingly, assuming that you are the consumer of the casing, the charges made for perforating same are subject to the tax in accordance with Ruling 15. Very truly yours,

E. H. Stetson
Tax Counsel

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