Ezel / Tax Rulings / CA

Were charges for public stenography, dictation, typing, and mimeographing taxable, and did the office need a seller's permit?

Short answer Stenography, dictation, and typing were nontaxable services. Mimeographing was taxable fabrication labor, so the office had to obtain a seller's permit.
State
CA
Ruling
Annotation 515.0220
Tax type
Sales and Use Tax
Issued
1961-01-01
Issued by
California State Board of Equalization
Requested by
A public stenography and secretarial-service office (identity redacted)
Topics
secretarial services mimeographing fabrication labor seller permits
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1961. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1961
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 opinion dated January 1, 1961, published by CDTFA as support for a sales and use tax annotation. It distinguishes public stenography, dictation, and typing from mimeograph fabrication and directs the described office to obtain a seller's permit. Another secretarial, transcription, copying, or document-production business should check current typing, transcription, reproduction, fabrication, digital-delivery, seller-permit, 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

California treated public stenography as a nontaxable service. That service treatment included taking dictation and typing.

Mimeographing was different. Under the referenced ruling and section 6006(b), it was fabrication labor and therefore taxable.

Because the office offered taxable mimeographing, California directed it to obtain a seller's permit.

What this means for you

Secretarial and document-production businesses

The source separated transcription and typing from mechanical reproduction, even when one office offered both.

Accountants and tax professionals

Track each service line, production method, charges, customer materials, permit obligations, and taxable receipts.

Common questions

Q: Was public stenography taxable?

A: No.

Q: Was mimeographing taxable?

A: Yes.

Q: Did the office need a seller's permit?

A: Yes.

Citations and references

  • California Revenue and Taxation Code § 6006(b)
  • Sales Tax Ruling 24 (referenced in the source)

Source

Original ruling text

515.0220

January 1, 1961
Gentlemen:
This is in reply to your letter of December 15, 1960, concerning the applicability of sales tax to your operation. You say you operate a public stenography office covering all types of secretarial service, including mimeographing. In general, public stenography is the sale of a service and not covered by the California Sales Tax Law. This includes taking dictation and typing. Mimeographing, however, is considered under Ruling 24, copy enclosed, as fabrication labor and, thus, within the definition of Section 6006(b) of the California Sales and Use Tax Law, copy enclosed. You should obtain a seller’s permit from the district office nearest you, which is located at 108 West 6th Street, San Bernardino. Our representative there will be happy to answer any further questions you might have concerning sales tax. Very truly yours, E. H. Stetson Tax Counsel By John H. Knowles JHM/o’b [at]

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