Ezel / Tax Rulings / TX
TX 8411L0603B12 Sales and/or Use Tax (State,Local,MTA) 1984-11-12

Did a Texas county have to collect tax on golf-course green fees and golf-cart sales or rentals?

Short answer: The county did not collect tax on green fees because county-provided amusements were specifically exempt from amusement tax. Its sales or rentals of taxable items such as golf carts were taxable.

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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 a county would not collect tax on golf-course green fees because amusements provided by counties were specifically exempt from amusement tax.

The county itself was exempt from tax on purchases for its own use. But its sales or rentals of taxable items, with golf carts given as the example, were taxable.

The ruling body addresses a county golf course. It does not discuss a city or a fair, despite the broader STAR subject label.

What this means for you

County golf-course operators

The 1984 letter distinguished the green fee from separate sales or rentals of taxable property.

Golf-cart operations

County ownership did not make a sale or rental of a taxable item nontaxable under this letter.

Accountants and tax professionals

Keep the county's own purchases, green-fee receipts, and golf-cart transactions in separate tax categories.

Common questions

Q: Did the county collect tax on green fees?
A: No. The letter said county-provided amusements were specifically exempt from amusement tax.

Q: Were county golf-cart sales or rentals taxable?
A: Yes, if they were sales or rentals of taxable items.

Q: Were the county's own-use purchases taxable?
A: No. The letter said counties were exempt on purchases made for their own use.

Citations and references

  • The letter cites no statute or administrative rule.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

November 12, 1984

Dear **:

Thank you for your recent letter concerning the taxability of golf
course green fees.

Counties are exempt from paying tax on purchases made for the counties
own use. Sales and/or rentals of taxable items such as golf carts made
by the county are taxable. The county will not collect tax on golf
course green fees since amusements provided by counties are specifically
exempt from amusement tax.

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,
Dot Burchard
Tax Policy Section
Tax Administration Division

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