Ezel / Tax Rulings / TX
TX 8605L0732A09 Sales and/or Use Tax (State,Local,MTA) 1986-05-19

Did a TR 200 Fat Cat two-wheel motorcycle qualify for the agricultural machinery and equipment exemption?

Short answer: No. The Comptroller said transportation was not agricultural use and no exemption was available for a two-wheel vehicle, even under the claimed farm-or-ranch use.

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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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 requester sought a farm-and-ranch exemption for a TR 200 Fat Cat motorcycle.

The Comptroller said agricultural exemptions applied only to machinery and equipment used exclusively on a farm or ranch to produce food or grass for sale in the regular course of business. A two-wheel vehicle did not qualify because transportation was not agricultural use.

Common questions

Was the motorcycle exempt? No.

Why not? The letter treated the two-wheel vehicle as transportation rather than agricultural-use equipment.

Source

Original ruling text

May 19, 1986

Dear ***:

Thank you for your letter requesting an exemption from sales tax for a
TR 200 Fat Cat Motorcycle.

Agricultural exemptions are granted only for machinery and equipment
used exclusively on a farm or ranch in the production of food or grass
to be sold in the regular course of business.

There is no exemption available for a two wheel vehicle since transportation
is not agricultural use. Enclosed is our agriculture brochure.

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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