Ezel / Tax Rulings / TX
TX 8607L0746G03 Sales and/or Use Tax (State,Local,MTA) 1986-07-22

Were hunting-lease operators required to obtain a permit or collect Texas sales tax while the Comptroller reconsidered its policy in July 1986?

Short answer: Temporarily, no. This letter superseded a May 9, 1986 letter and suspended permit and collection requirements for hunting-lease operations until a final determination was reached.

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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 letter published on STAR. It announced only an interim July 1986 suspension while hunting-lease policy was being reconsidered, superseding a May 9, 1986 letter; it did not state the later final determination and should not be treated as current law. Letters on STAR can support detrimental reliance only for the taxpayer directly addressed under the applicable rules, and STAR documents may no longer represent current policy. Identifying details are redacted. 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

The Comptroller superseded an earlier May 9, 1986 letter because its position on hunting leases was under reconsideration.

Until a final determination was reached, hunting-lease operations were not required to obtain a sales-tax permit or collect sales tax. The operative body did not decide hunting- or fishing-guide services generally, despite STAR's broader caption, and it did not include the later final policy.

Common questions

Were hunting-lease operators required to collect tax under this letter? Not during the stated reconsideration period.

Was this a final taxability determination? No. It expressly described an interim position pending further review.

Did the body decide fishing-guide services? No.

Source

Original ruling text

July 22, 1986

Dear ***:

This letter is meant to supersede my letter to you dated May 9, 1986.

Our position on hunting leases is being reconsidered. We will notify you
and other affected industry groups when we reach a final determination.
Until then, hunting lease operations will not be required to obtain a
permit or collect the sales tax.

Please feel free to contact us if you have additional questions. You may
write us, call toll free 1-800-252-5555 from anywhere in Texas.

Sincerely,

Tax Policy Section
Tax Administration Division

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