Ezel / Tax Rulings / TX
TX 8701L0787F01 Sales and/or Use Tax (State,Local,MTA) 1987-01-13

Were labor and material charges for repairing, painting, or lining railcars subject to Texas sales tax?

Short answer: No. Texas said railcar repairing, painting, and interior lining were nontaxable, including both labor and materials, whether the work occurred inside or outside Texas.

Apply this to your situation

This page answers the general question as of 1987. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1987
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 brief 1987 Texas Comptroller letter addresses repairing, painting, and lining railcars. The broader STAR caption mentions refurbishment and cleaning that the operative body does not separately decide. Rail, rolling-stock, repair, material, labor, interstate, sourcing, and local-tax rules may have changed. STAR documents may no longer represent current policy even when not marked superseded. Identities 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 Texas Comptroller said repairing, painting, and lining the interior of railcars were not taxable.

Texas tax did not apply to either material or labor charges, regardless of whether the work was performed inside or outside Texas. The body did not separately address the refurbishment and cleaning categories in STAR's broader caption.

What this means for you

The ruling treated the complete charge for the named railcar work as nontaxable and did not distinguish Texas work from out-of-state work.

Common questions

Was railcar repair taxable? No.

Were painting and interior lining taxable? No.

Were the materials taxable to the customer? No, under the letter.

Did location inside or outside Texas change the answer? No.

Citations and references

  • The letter cited no numbered statute or Comptroller rule.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

BOB BULLOCK
Comptroller January 13, 1987

Dear *****:

Thank you for your letter of December 19, 1986, concerning the taxability
of repairing, painting and lining the interior of rail cars.

Repairing, painting or lining of rail cars is not taxable. Texas tax
does not apply to either the materials or labor charges regardless
whether the service is done in or outside Texas.

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 me at
1-800-252-5555 toll free from anywhere in Texas. The regular number is
512/463-4600. You may write me at the Tax Administration Division.

Sincerely,
Eddie C. Washington
Tax Policy Section
Tax Administration Division

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