Ezel / Tax Rulings / CA

Did California sales tax apply to sales of human body parts for medical use?

Short answer No. The source states that sales tax did not apply to sales of human body parts for medical usage.
State
CA
Ruling
Annotation 540.0310
Tax type
Sales and Use Tax
Issued
1977-01-21
Issued by
California State Board of Equalization
Requested by
A requester whose identity is redacted
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1977. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1977
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 very brief California State Board of Equalization Tax Counsel confirmation letter dated January 21, 1977, published by CDTFA as support for a sales and use tax annotation. It states the agency's position on human body parts for medical usage but provides no facts, definitions, statutory analysis, or limits. Another taxpayer should not extend this historical staff statement beyond its words and should check current human-tissue, body-part, transplant, medical-use, sales-tax, use-tax, health-law, and other applicable 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 source confirms prior agency advice that California sales tax did not apply to sales of human body parts for medical usage.

The letter provides no additional facts or analysis. It does not define which body parts, transactions, medical uses, sellers, or recipients were within the stated position.

Citations and references

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

Source

Original ruling text

540.0310

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION
PO BOX 942879, SACRAMENTO, CALIFORNIA 94279-0001
TELEPHONE (916) 445-2641

January 21,1977

Mr. ----- --- ----- --- ---

Dear Mr. ---:
This will confirm our advice to you of January 14, 1977 that it is the position of the
State Board of Equalization that sales tax does not apply to sales of human body parts for
medical usage.
Very truly yours,

Gary J. Jugum
Tax Counsel

-- District Administrator

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