Ezel / Tax Rulings / CA

Were charges taxable for tanning consumer-owned hides and for manufacturing gloves from customer-furnished leather?

Short answer Yes. Tanning was a production step, and making gloves from consumer-furnished leather was taxable producing, fabricating, or processing.
State
CA
Ruling
Annotation 435.1660
Tax type
Sales and Use Tax
Issued
1951-01-02
Issued by
California State Board of Equalization
Requested by
A glove manufacturer asking about customer-furnished leather and tanning charges on hides
Topics
tanning gloves customer furnished property fabrication labor processing
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1951. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1951
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 January 2, 1951, published by CDTFA as support for a sales and use tax annotation. It applies historical Ruling 15 to consumer-furnished leather and hides and does not address resale processing. Another taxpayer should not treat it as binding and should check current tanning, leather, glove-manufacturing, fabrication, customer-furnished-material, 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

Manufacturing gloves from leather furnished by consumers was taxable producing, fabricating, or processing under Ruling 15.

Tanning a hide for the consumer of the resulting leather was also taxable. Tanning was a step in the series of operations creating tangible personal property.

Citations and references

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

Source

Original ruling text

435.1660

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

January 2, 1951

Gentlemen:
This is in answer to your letter of December 20 with respect to the application of the State sales tax to your charge for manufacturing gloves from leather furnished to you by your customers. As indicated by Sales and Use Tax Ruling 15, copy enclosed, the tax applies to charges for producing, fabricating, or processing tangible personal property for consumers who furnish, either directly or indirectly, the materials used. Accordingly, the tax will apply to your charge for manufacturing gloves for consumers who furnish the leather from which the gloves are produced. From the information in your letter it appears that you do not tan the hides furnished to you by your customers but you do state that they do not pay the tax with respect to the charges for tanning the hide. For your information, it is our opinion that the tax does apply to charges for tanning a hide for a consumer of the leather, pursuant to Ruling 15, as the tanning of the hide is a step in the process or series of operations resulting in the creation or production of tangible personal property, within the meaning of the second paragraph of said ruling. Very truly yours,

R. G. HAMLIN
Associate Tax Counsel
RGH:HB

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