TX 8410L0598E08 Sales and/or Use Tax (State,Local,MTA) 1984-10-19

How did Texas's October 2, 1984 tax change apply to seasonal and month-to-month fur storage already underway?

Short answer: Seasonal storage begun before October 2, 1984 stayed nontaxable even with monthly payments. Month-to-month storage was taxable for periods beginning after that date; the source's example has conflicting years and is not reliable.

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 Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. 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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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. Consult a licensed Texas tax professional about your specific situation.
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 said seasonal fur storage that began before October 2, 1984 was not taxable, even if the customer paid the seasonal charge through a monthly payment plan.

Furs brought in before that date under a month-to-month arrangement became taxable for monthly storage periods beginning after October 2, 1984. A monthly period beginning on or before October 1, 1984 was nontaxable.

The source's parenthetical example reads “September 15, 1985, to October 15, 1984,” which reverses the years and cannot be reconciled from the document. This page reports the stated period-start rule but does not silently repair that example.

What this means for you

Furriers and storage businesses

The letter distinguished one seasonal storage arrangement from a sequence of month-to-month periods.

Accountants and tax professionals

Use the explicit October 2 transition rule, not the source's internally inconsistent example. All treatment is historical.

Common questions

Q: Was pre-October 2 seasonal storage taxable?
A: No, even if paid monthly.

Q: What about month-to-month storage?
A: Periods beginning after October 2, 1984 were taxable.

Q: Is the date example in the source reliable?
A: No. It prints conflicting years.

Citations and references

  • The letter cites no statute or administrative rule.
  • The conflicting 1985-to-1984 example is preserved verbatim in the original text.

Source

Original ruling text

October 19, 1984




Dear **:

Thank you for your September 27, 1984 letter requesting written
confirmation of the verbal answer I gave you regarding the taxability
of certain fur storage charges.

Furs stored on a seasonal basis which were brought in for storage before
October 2, 1984, are not subject to the sales tax even if the customer
pays the seasonal storage on a monthly payment plan.

Furs which were brought in before October 2, 1984, but stored on a
month-to-month basis will be subject to sales tax for monthly storage
periods beginning after October 2, 1984. Monthly storage periods
beginning on or before October 1, 1984 (for example, September 15, 1985,
to October 15, 1984) will not be taxable.

This opinion is based upon the facts you presented. If there are
additional or different facts, this opinion may change.

Please feel free to contact me if you have additional questions. You
may write me, call toll free 1-800-252-5555 from anywhere in Texas or
phone 512/475-1931.

Sincerely,

Eddie C. Washington
Tax Policy Section
Tax Administration Division

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