Did out-of-state license plates exempt an automobile delivered to the buyer in California?

Plain-English summary

Sales tax applied because the automobile was delivered to the buyer in California. Obtaining out-of-state plates did not change the place of delivery or exempt the receipts.

The letter stated the broader rule that delivery to the buyer or the buyer's representative in California was taxable regardless of what the buyer later did with the property.

Citations and references

• California delivery rule for sales tax (stated without a section number in the source)

Source

• Annotated Legal Opinions collection: https://cdtfa.ca.gov/taxes-and-fees/annotations-menu.htm
• Annotation page: https://cdtfa.ca.gov/lawguides/vol2/suta/580-0000-all.html
• Original supporting opinion: https://cdtfa.ca.gov/lawguides/annotations/580-0220.pdf

Original ruling text

580.0220

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

June 24, 1953

Gentlemen:
In answer to your recent inquiry, we advise that the sales tax is applicable to the receipts from the sale of an automobile delivered to the buyer in California, regardless of the fact that out-of-state license plates are obtained for the car. Under the law the tax applies with respect to the sale of any property delivered to the buyer or his representative in this State, regardless of the buyer’s ultimate disposition of the property.

Very truly yours,

E. H. Stetson
Tax Counsel

EHS:ph
cc:

Stockton – Tax Administrator