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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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420.0000 Photographers, Photostat Producers, Photo Finishers and X-Ray Laboratories—Regulation 1528

Annotation 420.0325

(a) In General


420.0325 Third Party Furnishing Copies of Records. A hospital receives a subpoena or authorization letter to furnish copies of records. The hospital sends the subpoena or authorization letter to a copying service and makes its records available, at no charge, to the copying service. The copying service then performs the copying, delivers the copies to the requesting party, and bills the requesting party. Given such facts, tax applies to all charges by the copying service to the requesting party. Since the hospital did not make any charge to the copying service, the copying service cannot make a nontaxable statutory charge pursuant to sections 1158 or 1563 of the Evidence Code, regardless of how such charge is stated to the requesting party. 11/30/88.