Did paint thinner used by steamship operators become an exempt component part of watercraft?

Short answer No. The thinner evaporated as the paint dried, so California concluded that it did not become part of the vessel. Steamship-company representatives ultimately found no basis for treating the purchases as exempt.
State
CA
Ruling
Annotation 600.0620
Tax type
Sales and Use Tax
Issued
1952-05-19
Issued by
California State Board of Equalization
Requested by
Representatives of steamship companies disputing tax on paint thinner

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 a May 19, 1952 California State Board of Equalization tax-counsel letter published by CDTFA as support for a sales and use tax annotation. The official scan was visually reviewed because its embedded text layer is degraded; the printed letter date and section 6363 citation are legible on the page. It addresses thinner that evaporated during paint drying. 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

Steamship operators argued that paint thinner became part of watercraft and should receive the component-part exemption.

California rejected that position because the thinner evaporated during the paint-drying process. It therefore did not become a component part of the vessel.

The letter says company counsel found no basis for the exemption theory and that the companies had withdrawn or would withdraw their objections to paying sales-tax reimbursement to vendors.

What this means for you

Vessel operators, paint suppliers, and ship-repair contractors

Track what remains in the finished vessel. A material consumed or evaporated during application may be taxable even when the coating left behind becomes part of the watercraft.

Common questions

Q: Did thinner remain in the finished paint?

A: No. The source says it evaporated in drying.

Q: Did it qualify as a vessel component?

A: No.

Q: What happened to the companies' objections?

A: The letter says they had been or would be withdrawn.

Citations and references

  • California Revenue and Taxation Code § 6363, as printed in the source
  • California Sales and Use Tax Ruling 51.5, as cited in the source

Source

Original ruling text

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