Ezel / Tax Rulings / CA

Could a supplier accept a resale certificate when selling nonreusable paper covers for beverage glasses used in hotel room service?

Short answer Yes. The letter treated the disposable covers as sold with the room-service meal, so sales to hotels using them for that purpose were sales for resale.
State
CA
Ruling
Annotation 550.0420
Tax type
Sales and Use Tax
Issued
1956-06-01
Issued by
California State Board of Equalization
Requested by
A seller asking about disposable paper covers for hotel room-service glasses (identity redacted)
Topics
meals resale certificate resale exemption
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1956. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1956
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 June 1, 1956 tax-counsel letter addresses nonreusable paper covers for liquid-filled glasses used in hotel room service. Its resale treatment depends on that stated use and the cited historical rulings; reusable covers or other uses are not decided. Current law controls over the annotation. 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 supplier asked about nonreusable paper covers placed over glasses containing liquids used in hotel room service.

The letter treated the covers as items sold with the meal under Ruling 53. A supplier's sale of those covers to a hotel engaged in selling meals was therefore a sale for resale when the hotel used them for room service.

The supplier could accept a resale certificate from the hotel under Ruling 68 for those purchases.

Common questions

Did the covers have to be disposable?

The stated facts say they were not reusable, and the conclusion is limited to those facts.

Who could issue the resale certificate?

A hotel using the covers in its room-service meal business.

Did the letter address other uses of paper covers?

No. It addressed covers for liquid-filled glasses used in hotel room service.

Citations and references

  • Sales and use tax Ruling 53 (enclosed and cited)
  • Sales and use tax Ruling 68 (enclosed and cited)

Source

Original ruling text

STATE OF CALIFORNIA

550.0420

STATE BOARD OF EQUALIZATION

June 1, 1956

--- --- ----- --- ----- --- --Gentlemen:
In your letter of May 21, 1956, you inquire about the application of the State Sales Tax Law to sales of paper covers for glasses containing liquid used in room service of a hotel. The paper covers are not re-usable. We regard such covers as being sold with the meal pursuant to Sales and Use Tax Ruling 53, copy enclosed. Sales of such items for such purposes to persons engaged in the business of selling meals are, accordingly, sales for resale. It would be proper for you, as seller, to accept a resale certificate pursuant to Ruling 68, copy also enclosed, when any sales of the covers are made to a hotel which would use them in room service. Very truly yours,

W. W. Mangels
Associate Tax Counsel

JDP:nf

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