Ezel / Tax Rulings / TX
TX 8503L0621B01 Sales and/or Use Tax (State,Local,MTA) 1985-03-08

When were golf or tennis tournament entry fees not taxable under the corrected 1985 answer?

Short answer: Only when both conditions were met: the entry fee exceeded the usual green or court fee for the same period, and part of the fee funded tournament awards. The letter called this a clerical correction, not a policy change.

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This page answers the general question as of 1985. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1985
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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 March 1985 letter corrected a clerical error in an October 23, 1984 letter and expressly said the correction did not change policy.

A golf or tennis tournament entry fee was not taxable only if it was higher than the ordinary green fee or court fee for the same period of time and part of the fee went toward tournament awards. Both conditions had to be satisfied.

Common questions

Was exceeding the normal facility fee enough? No. Part of the fee also had to fund awards. Was funding awards alone enough? No. The fee also had to exceed the usual green or court fee. Did the Comptroller describe a new policy? No; it called the earlier wording a clerical error.

Citations and references

The reproduced letter cites no numbered statute or rule.

Source

Original ruling text

March 8, 1985

Dear ***:

My letter to you of October 23, 1984 contained a clerical error (not a
change in policy).

Entry fees for golf or tennis tournaments will not be taxable only if
the fee is higher than the usual green fee or court fee for, the same
period of time and if part of the fee will go toward awards for the
tournament. Both conditions must be met.

If you have any questions or need more information, please call us at
1-800-252-5555 toll free from anywhere in Texas. You may write us at the
Tax Administration Division.

Sincerely,

Tax Policy Section
Tax Administration Division

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