Ezel / Tax Rulings / CA

Were charges taxable for producing a perfectly typed copy that the customer would photograph and incorporate into a book or pamphlet?

Short answer No. California treated the typed copy as a reproduction proof under Business Taxes General Bulletin 62-3, so the typing charges were not taxable.
State
CA
Ruling
Annotation 515.0260
Tax type
Sales and Use Tax
Issued
1965-02-24
Issued by
California State Board of Equalization
Requested by
California Board of Equalization Santa Barbara auditing staff
Topics
typing services reproduction proof publishing
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1965. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1965
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 audit memorandum dated February 24, 1965, published by CDTFA as support for a sales and use tax annotation. It concerns a perfectly typed copy sold to a customer for photographic incorporation into a book or pamphlet and relies on Business Taxes General Bulletin 62-3's reproduction-proof treatment. Another typist, publisher, or production vendor should check current typing, typesetting, reproduction-proof, prepress, photographic, digital-file, publishing, 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 taxpayer produced a perfectly typed copy that the customer would photograph and incorporate into a book or pamphlet.

California concluded that the furnished copy qualified as a reproduction proof under Business Taxes General Bulletin 62-3.

The taxpayer's charges were therefore not taxable in those circumstances.

What this means for you

Typists, publishers, and production vendors

The ruling addressed a master copy used photographically in later publication production, not an ordinary sale of multiple finished copies.

Accountants and tax professionals

Document the copy's production purpose, photographic use, later incorporation, customer instructions, deliverables, and any additional copies.

Common questions

Q: Were the typing charges taxable?

A: No.

Q: How did California characterize the typed copy?

A: As a reproduction proof.

Citations and references

  • Business Taxes General Bulletin 62-3 (referenced in the source)

Source

Original ruling text

515.0260
Santa Barbara – Aud. (KRF)

February 24, 1965

Tax Counsel (PRD)

Since the taxpayer is furnishing a perfect typing service in which his perfectly typed copy will be sold to the customer who will photograph it for the purposes of incorporation into a book or pamphlet, it appears that Business Taxes General Bulletin 62-3 applies. No reason appears why the copy furnished by the taxpayer is not a "reproduction proof". Therefore, the taxpayer's charges are not taxable under these circumstances.

PRD:md [lb]

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