Ezel / Tax Rulings / TX
TX 7904L2024D01 Motor Vehicle Tax 1979-04-19

Were trailers built with chassis, axles, and wheels for highway towing treated as motor vehicles in Texas?

Short answer: Yes. Based on the described undercarriage, the trailers were motor vehicles for tax purposes and subject to motor vehicle sales tax. The purchaser owed the tax at title and registration, while the seller had to provide the transfer documents. The letter's 4% rate is obsolete.

Apply this to your situation

This page answers the general question as of 1979. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1979
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official Texas Motor Vehicle Sales Tax Division letter issued on one manufacturer's trailer design in 1979. STAR's subject incorrectly refers to NATO personnel; the operative body concerns towable trailers and controls this page. The quoted 4% rate and article 6.01 citation are obsolete. The letter predates modern Private Letter Ruling reliance terms and cannot bind the Comptroller for unrelated taxpayers. Vehicle definitions, tax base, title, and documentation rules may have changed. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page) is the authoritative source for any reliance.

Plain-English summary

The Texas Motor Vehicle Sales Tax Division said trailers constructed with chassis, axles, and wheels so they could be towed on public highways were motor vehicles for tax purposes.

The purchaser owed motor vehicle sales tax on total consideration after any qualifying motor-vehicle trade-in. Tax was paid to the county tax assessor-collector at title and registration.

The seller had to provide the documents needed to transfer title, including the historical Seller, Donor, or Trader's Affidavit.

STAR's NATO-related subject does not match the ruling body and is not used for the holding.

What this means for you

Trailer manufacturers and dealers

The historical classification depended on the towable highway undercarriage described.

Vehicle buyers

The letter placed tax payment on the purchaser and transfer-document duties on the seller.

Common questions

Q: Were the described trailers motor vehicles?

A: Yes.

Q: Is the letter's 4% rate current?

A: No.

Q: Does the body address NATO personnel?

A: No.

Citations and references

  • TEX. TAX-GEN. ANN. art. 6.01 et seq. — historical motor vehicle sales tax citation.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

BOB BULLOCK
Comptroller April 19, 1979

Dear ***:

Thank you for sending me the brochure describing the trailers which CORP
A
manufactures and sells in Texas. This letter is in response to your
inquiry
about the appropriate tax due upon the sale of these trailers.

*** of your Houston office confirmed by telephone today that
CORP
A's trailers are constructed with chassis, axles and wheels, so that they
may be transported by towing upon the highways. Provided that this is
the
design of the undercarriage, these trailers are motor vehicles for tax
pur-
poses and are subject to 4% Motor Vehicle Sales tax imposed by TEX.
TAX-GEN.
ANN. art. 6.01 et. seq. I am enclosing a copy of the statute for your
infor-
mation.

The Motor Vehicle Sales Tax is 4% of the total consideration paid or to
be paid
for the motor vehicle, less any value given for the trade-in of another
motor
vehicle. The tax is the obligation of the purchaser, to be paid to the
County
Tax Assessor-Collector at the time of titling and registration. The
seller's
obligation is to provide his purchaser with all documents necessary to
transfer
the title, including a correctly completed Seller, Donor, or Trader's
Affidavit.
I am sending some of these affidavits to ***, and more may be
obtained
at the local county courthouse.

I hope that this discussion will clarify the matter. If you have any
further
questions, please feel free to write to me at the Motor Vehicle Sales Tax
Division, or to call 512/475-6897, or to call toll free from anywhere in
Texas
1-800-252-5555, extension 133.

Sincerely,
Patricia Brockway
Division Attorney

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