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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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330.0000 Leases of Tangible Personal Property—In General—Regulation 1660

Annotation 330.3940

(d) "Substantial Change in Form"

330.3940 Boat and Motor. When a lessor purchases a boat from one vendor and a motor from another, both with tax-paid on the purchase price, and attaches the boat to the motor and then leases the boat with the motor attached, whether the property leased is in a substantially different form so as to subject the rentals to tax depends upon whether or not a significant amount of fabrication labor is required to attach the motor to the boat. If it is only necessary to bolt or clamp the motor in place this would not result in a substantial change in form. If, however, the boat must undergo significant alterations in order to install the motor, a substantial change in form would result. 8/31/66.