Ezel / Tax Rulings / CA

Did zinc electrodes used in an affixed vessel water-cooling system become exempt watercraft component parts?

Short answer Yes. California treated zinc electrodes used in a water-cooling system affixed to the vessel as component parts. The letter applied the same approach to replaceable filter elements for substantially attached engines and machinery.
State
CA
Ruling
Annotation 600.0700
Tax type
Sales and Use Tax
Issued
1951-02-16
Issued by
California State Board of Equalization
Requested by
A redacted inquirer about vessel filter elements and zinc electrodes
Topics
component parts
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1951. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1951
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 February 16, 1951 California State Board of Equalization tax-counsel letter published by CDTFA as support for a sales and use tax annotation. It concerns zinc electrodes used in an affixed vessel water-cooling system and filter elements for substantially attached engines and machinery. Other requirements of section 6368 still had to be satisfied. 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

California treated replaceable filter elements as vessel components when used in engines or machinery substantially affixed to watercraft.

It reached the same result for zinc electrodes used in a water-cooling system affixed to the vessel. Their replacement character did not prevent component-part status.

What this means for you

Vessel operators, marine-parts sellers, and tax advisers

Document the equipment receiving the replacement item and how that system is attached to the vessel. A replaceable item can still be a component when it operates within substantially affixed machinery.

Common questions

Q: Were zinc electrodes treated as vessel components?

A: Yes, when used in the affixed water-cooling system.

Q: Could replaceable filter elements also qualify?

A: Yes, for substantially attached vessel engines and machinery.

Q: Did the letter decide every exemption condition?

A: No. It addressed component-part status.

Citations and references

  • California Revenue and Taxation Code § 6368
  • California Sales and Use Tax Ruling 51.5, as cited in the source

Source

Original ruling text

600.0700

February 16, 1951

Re:
Gentiemen:
In answer to your letter of February 15, we advise that replaceable filter elements for engines and machinery which are affixed or attached to watercraft in a substantial manner when in use are regarded as becoming a component part of watercraft, within the meaning of section 6368 of the Sales and Use Tax Law and Sales and Use Tax Ruling 51.5. We believe that zinc electrodes are also properly regard­ ed as becoming a component part of watercraft where they are used in a water cooling system which is affixed to the watercraft.
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Very truly yours,

E. H. Stetson
Tax C9unsel
EHS:ph
cc:

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