Ezel / Tax Rulings / TX
TX 8408L0586B11 Sales and/or Use Tax (State,Local,MTA) 1984-08-28

Which vehicle, trailer, boat, wrecker, and transportation charges did Texas treat as taxable in Letter Ruling 8408L0586B11?

Short answer: Fees to store, park, or garage a motor vehicle—including a trailer—were taxable regardless of owner consent. A single charge for storing a boat on a trailer was not taxable. Wrecker and transportation fees were also not taxable when separately billed from storage fees.

Apply this to your situation

This page answers the general question as of 1984. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1984
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 1984 Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. It gives a historical classification without citing a statute or rule, so verify current storage, parking, wrecker, transportation, and local-tax law. Letters on STAR can be the basis of a detrimental reliance claim only for the taxpayer to whom the letter was directly issued (see 34 Tex. Admin. Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded. 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 Comptroller drew three lines among storage and transportation charges:

  • A fee to store, park, or garage a motor vehicle was taxable. The letter's examples included cars, trucks, trailers, and motorcycles, and it said owner consent did not change the result.
  • A single charge to store a boat on a trailer was not taxable.
  • Wrecker or transportation fees were not taxable when separately billed from storage fees.

The 1984 letter did not identify a statute, rule, tax rate, or sourcing provision.

What this means for you

Storage facilities

The historical distinction turned on what was being stored and how the charge was presented. Trailer storage was treated as taxable vehicle storage, while one combined charge for a boat on a trailer was not.

Towing and transportation businesses

Separate billing mattered. The letter protected wrecker and transportation fees only when they were separately billed from storage.

Accountants and tax professionals

Do not extend this short 1984 classification to current transactions without checking later law and the exact invoice structure.

Common questions

Q: Was a fee to store a trailer taxable?
A: Yes. The letter included trailers among motor vehicles whose storage, parking, or garaging fees were taxable.

Q: Was one charge to store a boat on its trailer taxable?
A: No.

Q: Were towing charges taxable?
A: The letter says wrecker and transportation fees were not taxable if separately billed from storage fees.

Citations and references

  • The letter does not identify a statute, rule, or legislative act.

Source

Original ruling text

August 28, 1984

Dear **:

Thank you for your letter dated August 22 and for your phone conversation today
inviting me to speak at your monthly association meeting September 6.

Tax is due on fees charged to store, park or garage a motor vehicle (cars,
trucks, trailers and motorcycles, regardless if you have consent from the
owner. Tax is not due on storing boats on trailers when a single charge is
made.

Tax is not due on wrecker or transportation fees if separately billed from
storage fees.

If you have additional information please call 1-800-252-5555 toll-free or
write me.

Sincerely,

Tom Gay
Tax Policy
Tax Administration Division

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