Ezel / Tax Rulings / TX
TX 8801L0871C11 Sales and/or Use Tax (State,Local,MTA) 1988-01-26

Was an exemption certificate printed on a specific purchase order acceptable as a Texas direct-payment exemption certificate?

Short answer: Yes. The purchase-order certificate contained the required language and was acceptable under Rule 3.288, but it covered only that specific purchase order and no other purchases.

Apply this to your situation

This page answers the general question as of 1988. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1988
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 January 1988 Texas Comptroller letter applying Rule 3.288. It says the opinion may change if the facts differ. The acceptance depended on the exact certificate containing required language and being issued for one specific purchase order. Direct-payment permits, certificate wording, purchase-order scope, seller acceptance, and recordkeeping rules may have changed; verify current law. STAR documents may no longer represent current policy even when not marked superseded. Company and taxpayer 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 exemption certificate printed on COMPANY A's purchase order contained the required language and was acceptable as a direct-payment exemption certificate under Rule 3.288.

It covered only that specific purchase order and did not apply to any other purchases.

What this means for you

The historical answer turned on both certificate wording and transaction scope. A certificate attached to one order was not a blanket certificate for later purchases.

Common questions

Was the certificate acceptable? Yes.

Did it cover future purchases? No, only the named purchase order.

Citations and references

  • 34 Tex. Admin. Code Rule 3.288 — historical direct-payment exemption certificate rule.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

January 26, 1988

Dear ***:

On behalf of Mr. Bullock, I hope you'll accept my apology for the delay
in
answering your question involving changes in the sales tax law. This
isn't
the way we normally do business.

Our people were, and still are, swamped by a deluge of inquiries as they
attempted to interpret provisions of the new law and draft rules which
would
not adversely impact businesses. In many instances, an answer to a
question
just wasn't available when the question arrived.

The exemption certificate on COMPANY A's purchase order is acceptable as
a
direct payment exemption certificate. The certificate contains the
required
language.

Please refer to Rule 3.288. The certificate was issued to cover a
specific
purchase order and would not cover any other purchases.

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 our
toll-free
number 1-800-531-5441. 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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