Ezel / Tax Rulings / TX
TX 8602L0694F04 Sales and/or Use Tax (State,Local,MTA) 1986-01-30

Were parking, canoe-rental, and customer-shuttle charges subject to Texas sales tax?

Short answer: Parking and canoe-rental fees were taxable, but separately stated charges for shuttling customers were not taxable.

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This page answers the general question as of 1986. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1986
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 1986 Texas Comptroller taxpayer-response letter based on separately stated charges for parking, canoe rental, and transportation of customers. It expressly says different facts could change the opinion. Current rental, parking, transportation, bundling, and sales-tax rules may differ, and STAR documents may no longer represent current policy even when not marked superseded. Letters on STAR can support detrimental reliance only for the taxpayer to whom the letter was directly issued under 34 Tex. Admin. Code Rules 3.1 and 3.10. 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 Comptroller said parking fees and canoe-rental fees were taxable. A separately stated charge for shuttling customers was not taxable.

The letter distinguished Sales Tax Review #96-237 because that review addressed transportation of tangible personal property, while this request involved transporting individuals.

Common questions

Was the canoe-rental charge taxable? Yes.

Was parking taxable? Yes.

Was the shuttle charge taxable? No, when separately stated under the facts presented.

Citations and references

  • Sales Tax Review #96-237 — distinguished because it addressed property transportation rather than transportation of individuals.

Source

Original ruling text

January 30, 1986

Dear ***:

Thank you for your letter concerning the taxability of parking, shuttle
and canoe rental charges.

Parking fees and canoe rental fees are taxable, however, separately
stated shuttle charges are not taxable.

Sales Tax Review #96-237 is addressing transportation of tangible
personal property rather than transportation of individuals.

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

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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