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Business Taxes Law Guide—Revision 2024

Transactions and Use Tax Annotations


820.0000 Place of Sale for Purposes of Transactions (Sales) and Use Taxes—Regulation 1822

Annotation 820.0085


820.0085 Delivery of Poster in BART Area. A taxpayer is in the business of printing signs and posters which are posted on billboards. The taxpayer will print a poster for a customer and deliver it to the installer in the BART district for pasting and posting on billboards outside the BART area. The customer pays the taxpayer for the poster and, also, pays the installing contractor directly.

Based upon the facts, the taxpayer is not required to ship the posters outside the BART area. Rather, the contract is merely for the delivery to the installing contractor inside BART. Accordingly, an exemption for ship-outs for these posters is not appropriate and the BART district tax applies to such deliveries in the BART area. 7/7/83.