Ezel / Tax Rulings / TX
TX 8605L0734C06 Sales and/or Use Tax (State,Local,MTA) 1986-05-30

Could a supplier accept an exemption certificate on products sold to chiropractors, and could chiropractors dispense vitamins, minerals, and food supplements without collecting sales tax?

Short answer: Yes. The supplier could accept the certificate; food supplements were exempt as food, and chiropractors could dispense vitamins and minerals tax-free as drugs and medicines.

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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 Executive Counsel letter published on STAR. It applies historical sales-tax treatment to one supplier's stated sales through chiropractors, lacks modern PLR or GIL reliance language, and should not be treated as binding by another taxpayer. Taxpayer-identifying details are redacted, and STAR documents may no longer represent current policy. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional.
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

A seller supplied vitamins, minerals, and food supplements to chiropractors, who resold them to patients.

Executive Counsel said the supplier could accept an exemption certificate on those items. Food supplements were exempt as food. Vitamins and minerals were treated as drugs and medicines, and chiropractors were practitioners of the healing arts who could dispense them without collecting sales tax.

Common questions

Could the supplier accept an exemption certificate? Yes.

Were food supplements taxable? No; the letter treated them as exempt food.

Could chiropractors dispense vitamins and minerals without collecting tax? Yes.

Source

Original ruling text

May 30, 1986

Dear ***:

You had met with me concerning your client, ***, *****
sells vitamins, minerals, and food supplements to chiropractors. The
chiropractors then resell these items to their patients.

You raised two questions:

  1. Can your client accept an exemption certificate on these items?

  2. If the chiropractors sell them to their patients, are the sales
    exempt as sales of drugs or medicines prescribed or dispensed by
    practitioners of the healing arts?

The answer to your first question is "yes."

As concerns your second question, food supplements are exempt as food.
We treat vitamins and minerals as drugs and medicines. Therefore,
chiropractors, as practitioners of the healing arts, may dispense
vitamins and minerals without collecting sales tax.

Should you have any additional questions, please call us.

Sincerely,

Executive Counsel

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