Ezel / Tax Rulings / TX
TX 8710L0843B11 Sales and/or Use Tax (State,Local,MTA) 1987-10-30

Were appraisals of art, antiques, furnishings, and personal property taxable when done for general value or for insurance purposes?

Short answer: General value appraisals were not taxable, but appraisals for insurance loss, damage, or coverage valuation were taxable insurance services.

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 is a taxpayer-specific October 1987 Texas Comptroller letter about personal-property appraisal services. It says the opinion may change if the facts differ. Its distinction between general appraisals and insurance-related appraisals under Rule 3.355 is historical; verify current classifications and taxability. STAR documents may no longer represent current policy even when not marked superseded.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 appraiser valued art, objects of art, antique furnishings, and other personal property for individuals, the public, and insurance companies.

The Comptroller said appraisals performed simply to determine those items' value were generally not taxable. Appraisals for insurance losses or damages, or to value property in connection with insurance coverage, were taxable as insurance services under Rule 3.355.

What this means for you

The historical letter classified the service by why the valuation was prepared. A general property-value appraisal was not taxable, while an appraisal tied to an insurance claim or coverage was taxable.

Common questions

Were ordinary value appraisals taxable? Generally no.

Were appraisals for insurance losses or damages taxable? Yes.

What about valuing property to obtain insurance coverage? That was also taxable as an insurance service.

Citations and references

  • Texas Comptroller Rule 3.355, insurance services referenced by the letter

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

October 30, 1987

Dear ***:

Thank you for your recent letter concerning your appraisal business.

You state that you are an appraiser of art, objects of art, antique
furnishings, and miscellaneous personal property. Services are available
to
the individual, general public, and insurance companies.

Question: Are these services taxable.

Answer: Appraisals for determining value of the above items are
generally
not taxable. However, appraisals for insurance loss or damages or to
value
property in connection with the furnishing of insurance coverage are
taxable
as insurance services. Please refer to Rule 3.355, enclosed.

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 Policy Division.

Sincerely,
(Mrs.) Jo Ann Dieck
Tax Policy Division

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