Tax Type
Retail Sales and Use Tax
Description
Photo processing
Topic
Exemptions
Property Subject to Tax
Date Issued
04-29-1986
April 29, 1986
Re: §58.1-1821 Application/Sales and Use Tax
Dear ********************
This will reply to your letter of March 5, 1986, in which you submit an application for correction of sales and use tax assessed to ************* as the result of a recent audit.
Your client is engaged in the operation of "one hour" photo processing laboratories and the sale of prints produced within the laboratories. Processing is performed by your client with respect to photographic film furnished by customers.
I have enclosed a copy of a recent ruling which sets forth the application of the sales and use tax to firms such as your client. As you will note in the ruling, the processing of customer furnished film has generally been deemed industrial in nature for purposes of the industrial manufacturing and processing exemption. Only in the event that the photo processing is incidental to the operation of a photography studio, camera shop, or similar business would the exemption be denied.
I have asked the department's Technical Services Section to review your client's audit in light of my recent ruling and to revise the audit if your client's processing operation is found to be industrial in nature.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner