Ezel / Tax Rulings / CA

Were charges taxable for printing or hand-painting textiles furnished by the customer?

Short answer Yes. Printing or hand-painting a consumer's textiles was taxable fabrication or processing of customer-furnished tangible personal property.
State
CA
Ruling
Annotation 435.1240
Tax type
Sales and Use Tax
Issued
1952-07-11
Issued by
California State Board of Equalization
Requested by
A textile business asking about charges for printing and hand-painting customer-furnished textiles
Topics
textiles printing 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 assistant-counsel letter dated July 11, 1952, published by CDTFA as support for a sales and use tax annotation. It applies historical Ruling 15 to printing and hand-painting consumer-furnished textiles without addressing repair, resale, or installation facts. Another taxpayer should not treat it as binding and should check current textile, printing, painting, customization, fabrication, processing, 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 business printed and hand-painted textiles supplied by its customers.

Ruling 15, as cited, treated fabrication or processing of tangible personal property for a consumer that furnished the property as a sale. The charges for both printing and hand-painting were therefore taxable.

Citations and references

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

Source

Original ruling text

435.1240

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

July 11, 1952

Account No. AD-12871

T--- A--- Company
XXXX --- ----- ---, California
Gentlemen:
This is in answer to your postcard of May 27 concerning the application of sales tax to your charges for printing and hand painting of textiles where your customer furnishes the textiles. As indicated in Sales and Use Tax Ruling 15, copy enclosed, the fabrication or processing of tangible personal property for a consumer who furnishes the property fabricated or processed is considered a sale for sales tax purposes. Accordingly, your charges for printing or hand painting textiles furnished by your customers are subject to sales tax. Very truly yours,

W. W. Mangels
Assistant Counsel

NBH:Ja

cc:

Wm. R. T---

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