Ezel / Tax Rulings / TX
TX 8605L0732A05 Sales and/or Use Tax (State,Local,MTA) 1986-05-19

How was tire-casing repair taxed when performed by the retreader itself versus a separate repair provider?

Short answer: The retreader's own casing repair was part of the retread process. A separate provider's repair was a taxable service, but the retreader could issue a resale certificate for services on tires it would resell.

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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 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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 casing repairs occurred only when a tire was going to be retreaded.

When the retreader performed the repair itself, the work was part of the retread process. When a separate entity repaired the casing, that entity performed a taxable service on tangible personal property.

The retreader could issue a resale certificate for repair services performed on tires that would be resold.

Common questions

Was the retreader's own casing repair separate from retreading? No.

Was an outside provider's repair service taxable? Yes.

Could the retreader buy that outside service for resale? Yes, for tires that would be resold.

Source

Original ruling text

May 19, 1986

Dear ***:

Thank you for your letter of May 5, 1986 concerning the repair of tire
casing.

You state in your letter that the repairs are done only in situations
where the tire is to be retreaded. If the repair is performed by ***,
it is a part of the retread process. If the repair is performed by a
separate entity, it is a taxable service performed on tangible personal
property. ***** may issue a resale certificate for services performed
on tires that will be resold.

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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