Ezel / Tax Rulings / CA

Were California retail sales of coins and stamps as collectors' items subject to sales tax?

Short answer Yes. The source treated collectible coins and stamps as taxable tangible personal property and said a person selling them in business needed a seller's permit.
State
CA
Ruling
Annotation 540.0160
Tax type
Sales and Use Tax
Issued
1952-03-10
Issued by
California State Board of Equalization
Requested by
A prospective California seller of collectible coins and stamps (identity redacted)
Topics
seller permits
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 an undated California State Board of Equalization Tax Counsel letter published by CDTFA as support for a sales and use tax annotation; the official annotation metadata supplies the March 10, 1952 date used here. It addresses coins and stamps sold as collectors' items and includes historical seller-permit, fee, return, and local-registration instructions. Another taxpayer should not treat this historical staff opinion as binding and should check current collectible-coin, collectible-stamp, legal-tender, seller-permit, local-business, sales-tax, 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

The letter said sales of coins and stamps as collectors' items were subject to California sales tax. A person engaging in that selling business had to obtain a seller's permit and report taxable sales.

The source enclosed a permit application, referred to a historical $1 application fee, and told the seller to ask city and county officials about local business requirements. Those administrative details reflect the source's historical period and should not be assumed current.

The supporting letter itself does not print a date. The March 10, 1952 date comes from the official annotation metadata.

Citations and references

  • The source letter cites no statute, regulation, or case by number.

Source

Original ruling text

540.0160

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

Dear Mr. ______:
Your letter of February 12 addressed to the Secretary of State has been referred to this Board for reply. You are advised that a person desiring to engage in business in this State as a seller of tangible personal property must obtain a permit from this Board. He must also pay the sales tax on his sales which are subject to the tax. In our opinion sales of coins and stamps as collectors’ items are subject to sales tax. Enclosed is an application for a seller’s permit together with a sample sales and use tax return. When filled in, the application should be presented, together with the $1.00 fee, to our Sacramento office, 1020 N Street. You should also inquire from county and city officials concerning the local requirements for your type of business. Very truly yours,

E.H. Stetson
Tax Counsel

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