In a mixed golf-resort/hotel/conference-center development on city-owned land, which pieces qualify for hotel-project tax rebates, and are the construction contracts tax-exempt?

Plain-English summary

This is an unusually detailed, ten-question ruling on a large mixed-use development combining a golf resort, a ~500-room hotel with conference space, and public golf facilities, all built on land a city will own but a private developer will control and operate. The Comptroller worked through which pieces qualify for the Chapter 351 hotel-project tax rebate and — in a separate but related question — whether the construction contracts for the whole project are tax-exempt.

Ancillary facilities split. Applying the same "exclusively sells tangible personal property" and "primarily used for convention events" tests as later companion ruling 201903025L, the Comptroller found retail shops that exclusively sell goods, restaurants, coffee shops, bars, and parking facilities DO qualify as rebate-eligible facilities ancillary to the hotel. But the spa and salon facility, a tennis shop that also sells court access (a service, not just goods), and the entire golf clubhouse (including any shops or restaurants inside it) do NOT qualify — consistent with the narrow "shop" definition excluding anything that isn't purely a retail goods seller.

Convention center complexity. The project's conference center is split into a main building and two annexes inside other structures; the Comptroller ruled each piece can separately qualify as a "convention center facility" if it's primarily used to host conventions/meetings and sits within 1,000 feet of the hotel — but if the developer later exercises an option to buy the conference center from the city, it stops being a city-owned convention center facility and the rebate math changes.

The exempt-contract question got a different (and negative) answer. Even though the city technically owns the underlying land, the Comptroller ruled the design and construction contracts for the ENTIRE project (golf facilities, conference center, hotel, and other business facilities) are NOT tax-exempt under § 151.311 — because the private developer, not the city, controls the facilities, collects the revenues, and holds cheap purchase options that could take the city's interest away entirely. This directly contrasts with the same-batch charter-school ruling (201901040L), where a long lease term relative to useful life WAS enough to establish the exempt organization's "primary use and benefit" — here, the developer's revenue rights and buyout options tipped the balance the other way even though the city legally owns the land.

Mixed beverage tax clarification: the city's 10.7143% statutory share of mixed beverage taxes citywide is separate from, and not part of, any hotel-project rebate.

What this means for you

Municipalities negotiating large mixed-use hotel/resort developments

The "who really benefits" analysis for the construction-materials tax exemption is SEPARATE from the "which facilities qualify for revenue rebates" analysis — a project can have some facilities that qualify for rebates while its construction contracts entirely fail the exempt-contract test, if the developer (not the city) retains the practical control, revenue, and purchase-option leverage. Structure ownership, revenue splits, and purchase options carefully if you want the construction exemption too, not just the operating-revenue rebate.

Golf resort and hospitality developers

Ancillary golf-related facilities (clubhouse, pro shop with course access sales) and wellness facilities (spa/salon) are consistently excluded from hotel-project ancillary-facility status across multiple Comptroller rulings — budget for full sales tax on materials/construction and full sales tax exposure on operating revenue for those specific components, even within an otherwise-qualifying hotel project.

Bond counsel and municipal finance officers

This ruling's ten-question structure is a comprehensive template covering nearly every recurring issue in Chapter 351 hotel-project financing: eligible central municipality qualification, convention-center-facility definition (including split/annexed conference centers), ancillary-facility scope, rebate entitlement mechanics, mixed beverage tax allocation, and the application process — worth reading in full for any comparable deal.

Common questions

Q: Does a golf clubhouse ever qualify as a facility ancillary to a hotel?
A: Not in this ruling — the golf clubhouse, along with any shops or restaurants inside it, was excluded, along with the spa/salon and the tennis shop (because it sells court access, a service, alongside goods).

Q: If a conference center is split into a main building and separate annexes, does that break its convention-center-facility status?
A: No — each piece can separately qualify as long as it's primarily used for conventions/meetings and located within 1,000 feet of the hotel, per this ruling.

Q: Why weren't the construction contracts tax-exempt if the city legally owns the land?
A: Because § 151.311 exemption turns on which party gets the PRIMARY USE AND BENEFIT of the improvements, not just legal land ownership — here the developer's revenue rights and low-cost purchase options meant the developer, not the city, was the real beneficiary.

Q: Can another city or developer rely on this ruling?
A: No. It binds the Comptroller only as to the taxpayer and facts in this specific request and cannot be relied on by any other taxpayer, though its facility-by-facility and contract-benefit analysis is a useful template for structuring comparable deals.

Citations and references

Statutes and rules:

• Tex. Tax Code § 351.102(b), (c); § 351.001(2), (7)(C)
• Tex. Tax Code § 151.429(h); § 151.309(5); § 151.311
• Tex. Tax Code § 183.051 (Mixed Beverage Tax Clearance Fund)
• Tex. Gov't Code § 2303.003(8), § 2303.5055; § 1504.001(a)(2)
• 34 Tex. Admin. Code Rule 3.291(a)(5), (c)(2)(B)
• Putman v. City of Irving, 331 S.W.3d 869 (Tex. App.-Dallas 2011, pet. denied)
• Comptroller's Decision Nos. 44,896, 47,235 (2009); No. 41,946 (2003)
• STAR Accession Nos. 201803042L (2018), 201405903L (2014), 200108598L (2001)

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/201811002L

Original ruling text

NOTE: This document is also indexed as a hotel tax occupancy document under STAR 201811003L.

November 20, 2018

RE: Private Letter Ruling No. 20181001160142

Dear ** and **:

We issue this private letter ruling in accordance with Rule 3.1, Private Letter Rulings and General Information Letters. [ENDNOTE 1] We are responding to your request dated Sept. 28, 2018, supplemental letter dated Oct. 25, 2018, and email message dated Nov. 6, 2018. Detrimental reliance relief is provided in accordance with Rule 3.10, Taxpayer Bill of Rights.

You requested guidance on whether the described hotel project is a qualified hotel project that entitles the city of ** (City) to a rebate or refund of taxes under Section 151.429(h) (Tax Refunds for Enterprise Projects) and Government Code Section 2303.5055 (Refund, Rebate, or Payment of Tax Proceeds to Qualified Hotel Project), pursuant to Section 351.102(c) (Pledge for Bonds).

You also requested guidance on the exemption in Section 151.311 (Taxable Items Incorporated Into or Used for Improvement of Realty of an Exempt Entity) for tangible personal property and taxable services purchased for use in the performance of a contract to improve realty for an organization exempt under Section 151.309 (Governmental Entities). You asked if the design and construction contracts for the golf facilities, conference center, and hotel project are “exempt contracts,” and whether taxable services and materials purchased under the contracts are exempt from state and local sales and use taxes under Rule 3.291 (Contractors).

This response addresses a “hotel project” rather than a “qualified hotel project.” Government Code Section 2303.003(8) (Definitions) defines “qualified hotel project” to apply to “a municipality having a population of 1,500,000 or more,” which is currently only the City of Houston.

Facts Presented

The relevant facts are based on the information provided in the initial request and supplemental submissions with attachments.

The City, COMPANY A, and COMPANY B on behalf of COMPANY C (Developer), intend to enter into a Master Development Agreement (MDA) to develop, finance, and operate a golf-related development. The development will include a COMPANY A global headquarters facility and education center (headquarters facility), golf facilities, and a hotel project. The headquarters facility will be located on private land. The golf facilities and hotel project will be located on land owned by the City. The MDA contemplates design and construction contracts for the golf-related development between the Developer and contractors.

The Hotel Project and Conference Center

The MDA provides that the Developer construct a golf resort hotel facility with conference center space and other business facilities. The hotel facility will include approximately 500 rooms, indoor and outdoor meeting spaces, dining and event spaces, conference center space, and indoor and outdoor recreational facilities (pools, hot tubs, and putting green).

The Developer will convey the land to the City for the hotel facility and other business facilities. The City will execute the Hotel Ground Lease to lease the land for a term of 10 years to the Developer to construct the hotel facility and other business facilities. The MDA requires the Developer to use the land for the primary purpose of operating the hotel facility.

The Developer will have the right to all revenues generated from the hotel facility and other business facilities. Except for the conference center, the Developer will own the hotel facility and other business facilities during and after the term of the hotel ground lease. The Developer will have an option to purchase the land after 20 years for one hundred dollars or at any time during a ten-year option period for ten thousand dollars.

The other business facilities are likely to include:

inside the hotel facility, a spa and salon facility, retail shops, food and beverage outlets, a tennis shop that sells and rents tennis-related items and access to the tennis court, and parking facilities;

outside the hotel facility, retail shops selling golf-related items, and golf clubhouse, which includes restaurants, coffee shops, bars, sale and rental of golf-related items, reservations for the golf facilities, and clubhouse memberships.

The request and subsequent information provides the Developer will construct 127,000 square feet of conference center space as three or more separate facilities. The main conference center will be located in a separate building adjacent to the hotel building and will comprise approximately 95,250 square feet. Each of the two conference center annexes will be located within the hotel facility or within a building housing other business facilities and together will comprise approximately 31,750 square feet. The main conference center and two conference center annexes will constitute the conference center.

The Developer will convey title of the conference center to the City, and the City will enter into an operating lease with the Developer to operate the conference center. The operating lease requires the Developer to use the conference center for a public conference, meeting, and exhibit center to hold conventions, meetings, and events to attract conventions and tourists. The City and City Independent School District (CISD) may collectively use the conference center for 10 days per year at no cost, but only when available. The City asserts that the convention center will be for the benefit of the City.

The Developer will retain net revenue from the conference center and will have an option to purchase the conference center under an agreement with the City for the fair market value of the conference center with deduction for capital expenditures and other costs.

Golf Facilities

The MDA requires the Developer to acquire a parcel of land and convey it to the City. In turn, the City will combine that parcel with another City-owned parcel to create the tract for the golf facilities. The City will lease the tract to the Developer to construct the golf facilities. The City will own the completed golf facilities pursuant to Government Code Section 1504.001(a)(2) (Authority for Certain Facilities). The City asserts that the golf facilities will be for the benefit of the City.

The golf facilities will include a public 18-hole championship-caliber golf course designed to host major golf championships, and a second public 18-hole golf course designed as a general recreational resort-style course. The MDA requires the City and the Developer to enter into a lease for the golf facilities (Golf Facilities Lease), which will last for a term of twenty-five years with an automatic extension of one fifteen-year period followed by two ten-year periods. The MDA provides COMPANY A or an affiliate will host a set amount of golf tournaments at the golf facilities. The Golf Facilities Lease provides the golf facilities will be open to the public at all times except when the Developer, the City, or the CISD are using the golf facilities. The MDA provides that COMPANY A or an affiliate will supervise, manage, and operate the golf facilities.

COMPANY A and Developer events will have priority over City and CISD events. Developer also has the right to restrict access to the hike and bike trails that are within the golf facilities. The City may use the golf facilities up to five days a year free of charge, provided the Developer and COMPANY A agree.

The City will grant the Developer a purchase option to purchase fee simple title to the golf facilities. If the City is not able to transfer fee simple title to any portion of the golf facilities, the City will grant Developer an exclusive easement to provide complete control over the use of the entire golf facilities as if the entire golf facilities had been conveyed to the Developer in fee simple. Under the purchase option, the purchase price for the golf facilities will be one hundred dollars.

During the term of the Golf Facilities Lease, Developer will pay an annual base rent for the first five years with a two percent increase each year going forward. Developer will be entitled to all revenues from any source generated by the golf facilities. Developer will pay the City two percent of the revenue derived from the naming rights of the golf facilities. Developer has the sole right to grant and enter into licenses, management agreements, and any agreements relating to the golf facilities. COMPANY A is a third party beneficiary with the right to enforce the obligations of the City and the Developer under the MDA to the same extent as the Developer and the City.

Questions, Rulings, and Analysis

Our restatement of your questions are shown below, followed by our responses and analysis.

Question One: Does the City qualify as an “eligible central municipality?”

Ruling One: The City will qualify as an eligible central municipality under Section 351.001(7)(C) (Definitions) upon adoption of a capital improvement plan to construct a conference center that is a convention center facility defined in Section 351.001(2).

Question Two: Is the conference center a “convention center facility owned by the City” as referenced in Section 351.102(b)? Will the hotel facility still qualify as a hotel project if only one conference center component is located within 1,000 feet of the hotel facility?

Ruling Two: The main conference center and the conference center annexes that are within a 1,000 feet of the hotel and are used primarily to host conventions and meetings may each qualify as convention center facilities owned by the City under Section 351.102(b).

The City may still qualify for a hotel project if the hotel is located within 1,000 feet of a conference center component that is a convention center facility. However, the facilities ancillary to the hotel must be located within 1,000 feet of that convention center facility or the hotel.

Should the Developer exercise its option to purchase the conference center during the ten-year rebate period, the conference center will no longer be a convention center facility owned by the City.

Question Three: Does the hotel facility meet the requirements of a “hotel project” under Section 351.102(b)?

Ruling Three: No, the entire hotel facility is not a hotel project. Certain components of the hotel facility, however, may meet the requirements of a hotel project.

Analysis for Rulings Two and Three: Section 351.102(b) provides that a hotel project for the City is:

a hotel that is owned by, or located on land owned by the City and located within 1,000 feet of an operational convention center facility owned by the City; and

any facilities ancillary to the hotel that are owned by, or located on land owned by, the City, including convention center entertainment-related facilities, meeting spaces, restaurants, shops, street and water and sewer infrastructure necessary for the operation of the hotel or ancillary facilities, and parking facilities located within 1,000 feet of the hotel or convention center facility.

Section 351.001(2) defines “convention center facilities” as “facilities primarily used to host conventions and meetings. The term means civic centers, civic center buildings, auditoriums, exhibition halls, and coliseums that are owned by the municipality or other governmental entity or that are managed in whole or part by the municipality.”

If the conference center meets the definition of a convention center facility, the conference center will qualify as a convention center facility.

The entire hotel facility described by the City does not qualify. The hotel and other business facilities that meet the definition of facilities ancillary to the hotel may qualify as a hotel project.

Question Four: Are the other business facilities “facilities ancillary to the hotel” under Section 351.102(b) such that the City may receive the tax rebates described in Government Code Section 2303.5055 and Section 151.429(h), pursuant to Section 351.102(c)?

Ruling Four: Retail shops that exclusively sell tangible personal property, restaurants, coffee shops, bars, and parking facilities qualify as facilities ancillary to the hotel. The facilities must meet the ownership and distance requirements in Section 351.102(b) and be constructed, developed, or remodeled as part of the hotel project.

A spa and salon facility, retail shops that sell services or sell services and tangible personal property, the golf clubhouse, and any shops or restaurants within the golf clubhouse do not qualify as facilities ancillary to the hotel.

Analysis for Ruling Four: Section 351.102(b) uses but does not define the term facilities ancillary to the hotel. Section 351.102(b), provides that the facilities ancillary to the hotel are part of the hotel project. A hotel project must be owned by or located on land owned by the city or, for an eligible central municipality, by a nonprofit corporation acting on its behalf. Therefore, the facilities ancillary to the hotel must also be owned by or located on land owned by the city or a nonprofit corporation acting on behalf of an eligible central municipality. Section 351.102(b) further provides that facilities ancillary to the hotel must be located within 1,000 feet of either the hotel or the convention center facility.

The Tax Code references “ancillary” in various sections, such as:

“[g]roup of manufacturing and processing machines and ancillary equipment that together are necessary to create or produce….” Section 151.0047(b)(2) (Real Property Repair and Remodeling);

“…[p]iping through which the product … is recycled or circulated in a loop between the single item of manufacturing equipment and the ancillary equipment that supports only that single item of manufacturing equipment….” Section 151.318(c)(1)(B) (Property Used in Manufacturing); and

“… ‘[q]ualified property’ means … tangible personal property… that is first placed in service in the new building … if the personal property is ancillary and necessary to the business conducted….” Section 313.021(2)(C)(iii) (Definitions).

The Oxford Living Dictionaries defines “ancillary” as “providing necessary support to the primary activities or operation of an organization, institution, industry, or system.” Oxford Living Dictionaries, 2018, (https://en.oxforddictionaries.com/defintion/ancillary). The decision in Putman v. City of Irving, 331 S.W.3d 869 (Tex. App.–Dallas 2011, pet. denied) states that the facilities do not have to be physically connected to the hotel and the restaurants do not have to derive the majority of their revenue from hotel guests to qualify as “ancillary.” Putnam, 331 S.W.3d at 876. Therefore, the term facilities ancillary to the hotel means facilities that provide necessary support for the operation and function of the hotel.

Section 351.102(b) includes the term “shops” as a facility ancillary to a hotel, but does not define the term therein. Merriam-Webster's Dictionary defines “shop” as “a building or room stocked with merchandise for sale: store.” Merriam-Webster Dictionary, 2018, (https://www.merriam-webster.com/dictionary/shop). The term shop means a retail store that exclusively sells tangible personal property.

The other business facilities that are facilities ancillary to the hotel may qualify for rebates of sales and use taxes and mixed beverage sales taxes are the retail shops that exclusively sell or rent tangible personal property, parking facilities, coffee shops, restaurants, and bars. The facilities must meet the ownership and distance requirements in Section 351.102(b).

The following other business facilities do not qualify as facilities ancillary to the hotel: a spa and fitness facility, a tennis shop that sells access to the tennis court along with selling and renting tennis-related items, and the golf clubhouse, including any shops or restaurants within the golf clubhouse.

Finally, the area of a hotel project may encompass existing facilities within 1,000 feet of the hotel or convention center facility. Because existing facilities may be built prior to and independent of the development of a hotel project, the definition excludes existing facilities located within 1,000 feet of the hotel or convention center facility that are not constructed, developed, or remodeled as part of the hotel project.

Question Five: Is the City entitled to receive tax rebates described in Section 151.429(h) and Government Code Section 2303.5055 that are generated at the hotel project?

Ruling Five: Under Section 351.102(c), the City is entitled to rebates from the hotel and the other business facilities that qualify as facilities ancillary to the hotel as described in Ruling Four.

Analysis for Ruling Five: Section 351.102(c) provides that a city to which Section 351.102(b) and Section 351.102(e) applies is entitled to receive the taxes generated at its a hotel project that the owner of a qualified hotel project may receive under Section 151.429(h) and Government Code Section 2303.5055. Section 151.429(h) allows the owner of a qualified hotel project to receive the state sales and use taxes and state hotel occupancy taxes generated at the project for ten years after the hotel’s initial opening. Government Code Section 2303.5055 allows the owner of a qualified hotel project to receive over the same ten-year period the ad valorem taxes, local sales and use taxes, local hotel occupancy taxes, and local mixed beverage taxes that a governmental body agrees in writing to rebate the city.

Question Six: Will the City receive rebates of taxes generated by the other business facilities that qualify as facilities ancillary to the hotel even though neither the City nor the Developer will own the businesses that rent the space and provide the goods or services?

Ruling Six: Yes, the other business facilities that qualify as facilities ancillary to the hotel, described in Ruling Four, are located on land owned by the City as required under Section 351.102(b).

Analysis for Ruling Six: Section 351.102(b) does not require the City or the Developer to own the facilities ancillary to the hotel as long as the City owns the land upon which the ancillary facilities are located, and the facilities are constructed, developed, or remodeled as part of the hotel project.

Question Seven: Would the total amount of mixed beverage taxes received by the City from the hotel project be equal to 10.7143% of the total of mixed beverage gross receipts taxes and mixed beverage sales taxes collected by the State at the hotel project?

Ruling Seven: Pursuant to Section 183.051 (Mixed Beverage Tax Clearance Fund), the City receives 10.7143% of the mixed beverage gross receipts and mixed beverage sales taxes remitted to the State from all mixed beverage permittees located within the City. The City is not entitled to receive rebates of state mixed beverage taxes. See STAR Accession No. 201803042L (March 16, 2018).

Question Eight: What is the process for obtaining the tax rebates?

Ruling Eight: Below are the current agency requirements to initiate a request for tax rebates. The City should submit a written request to the Comptroller’s Audit Division along with the following required information:

copy of the Certificate of Formation for Developer;

copy of the City’s Capital Improvement Plan;

copy of the architectural plan for the hotel project;

a map that shows the distances between the hotel project, including facilities ancillary to the hotel, and the convention center facility;

records from Developer and the City, such as guest folios and press releases, which show the date when the hotel project was or will open for initial occupancy;

name and address of the hotel and the Comptroller-issued taxpayer identification and location number that the hotel is using, or will use, to report sales and use, hotel occupancy, and mixed beverage taxes;

name and Comptroller-issued taxpayer identification and location numbers of each facility ancillary to the hotel;

waiver of confidentiality releases signed by the authorized officer or director of the hotel and each facility ancillary to the hotel allowing the Comptroller to release the facility’s sales and use tax and mixed beverage sales tax information to the City. A waiver of confidentiality release must be renewed annually, unless it specifically states that it is in effect for three years. The Comptroller will not approve a period longer than three years;

name and telephone numbers of the contact person for the municipality; and

completed direct deposit authorization form from the municipality.

After review, the Comptroller’s office will give the City written notice as to the results of that review and will initiate the rebate process as appropriate.

Question Nine: Assuming the Comptroller’s Office approves the hotel project for tax rebates, what would be the general timeline for payment of the rebates after the taxes are received by the Comptroller?

Ruling Nine: The rebates will be for the first 10 years after the hotel is open for initial occupancy and the convention center facilities are operational. The Comptroller’s office will make monthly payments of state sales and use taxes and state hotel occupancy taxes. The Comptroller allocates mixed beverage taxes quarterly under Section 183.051(b) to cities.

Question Ten: Are the design and construction contracts for the golf facilities, the conference center, and the hotel project executed pursuant to the MDA considered “exempt contracts?”

Ruling Ten: The design and construction contracts for the golf facilities, the conference center, and the hotel project executed pursuant to the MDA are not considered “exempt contracts” under Section 151.311.

Analysis for Ruling Ten: Section 151.311 exempts from sales and use tax certain purchases of taxable items for use in the performance of a contract for an improvement to realty for exempt entities. This exemption applies even when the contract is between a nonexempt entity and a contractor, if the contract is an “exempt contract.” Comptroller’s Decision Nos. 44,896 and 47,235 (2009). Rule 3.291(a)(5) defines an “exempt contract” as “a contract with a nonexempt entity to improve real property for the primary use and benefit of an organization exempted under Tax Code, §151.309 . . . .”

Rule 3.291(c)(2)(B) further provides, “A contract with a private party to improve real property owned by an exempt entity, other than a governmental entity described in Tax Code, §151.309, is not an exempt contract if the improvement to real property is for the primary use and benefit of the private party.” See also Comptroller’s Decision No. 41,946 (2003); STAR Accession No. 201405903L (May 9, 2014); STAR Accession No. 200108598L (Aug. 20, 2001).

The design and construction contracts contemplated by the MDA involve the incorporation of tangible personal property for the improvement of real property. The City is an exempt entity under Section 151.309(5). The Developer will acquire and convey a portion of the land for the golf facilities to the City. The City will lease the combined tract to the Developer for the construction of the golf facilities. The Developer will also convey the land to the City for the hotel facilities, other business facilities, and conference center. The City will lease the land to the Developer for construction and management of the facilities.

The City will not be a party to the design and construction contracts. Therefore, to qualify for the exemption under Section 151.311, the design and construction contracts for the golf facilities, hotel facility, other business facilities, and conference center must be for the primary use and benefit of the City.

The Developer and COMPANY A control the use of the golf facilities, receive all revenues, and have the ability to restrict the City and the public’s access to use the golf facilities. The Developer controls the use of the hotel facility, other business facilities, and conference center; and receives all revenues.

Furthermore, Developer has the ability to purchase for a nominal price the golf facilities, land beneath the hotel facility and the other business facilities, and the conference center prior to the expiration of the lease. If the Developer exercises this option, the City no longer has an interest in the land or the improvements.

The design and construction contracts contemplated by the MDA will not be for the primary use and benefit of the City. Based on the provisions in the MDA and lease agreements concerning the control and ownership of the golf facilities and the receipt of revenues from the facilities, the Developer and COMPANY A receive the primary use and benefit of the golf facilities. For the same reasons, the Developer receives the primary use and benefit of the hotel facility, other business facilities, and conference center. Therefore, the contracts contemplated by the MDA are not exempt contracts under Rule 3.291(a)(5) and do not qualify for exemption under Section 151.311.

Comptroller’s Decisions and STAR documents cited can be found on the Comptroller’s State Tax Automated Research (STAR) system. The Texas Tax Code, Texas Administrative Code, and the STAR system are accessible at www.comptroller.texas.gov/taxes/.

If you have questions about this private letter ruling, please email us through our website at https://comptroller.texas.gov/web-forms/tax-help/ and reference Private Letter Ruling No. 20181001160142.

Sincerely,

Tax Policy Division – Indirect Taxes

Texas Comptroller of Public Accounts

ENDNOTE

1. Unless otherwise indicated, all references to “Government Code” are to the Texas Government Code, all references to “Section” are to the Texas Tax Code, and all references to “Rule” are to Title 34 of the Texas Administrative Code.