Ezel / Tax Rulings / TX
TX 8804L0868G06 Sales and/or Use Tax (State,Local,MTA) 1988-04-19

Were a record-storage facility's charges for document pickup, storage, and certified shredding taxable, and what about its garbage-company charge?

Short answer: The facility's pickup, storage, and shredding charges were not taxable. The facility had to pay sales tax on the garbage collection company's charge for hauling away the shredded material.

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 an official 1988 Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. Its conclusion applies to the described record facility's pickup, storage, certified shredding, and outsourced garbage disposal; verify current service classifications before using it today. Letters on STAR can support detrimental reliance only for the taxpayer directly issued the letter and may no longer represent current policy. Taxpayer-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

A Texas record-storage facility picked up documents and film—or removed them from its shelves—and shredded them so they could not be identified. The shredded material went into a leased dumpster that a garbage company collected weekly.

The Comptroller said the facility's charges for pickup, storage, and shredding were not taxable. The facility itself had to pay sales tax on the garbage collection company's charges.

What this means for you

Under this 1988 letter, the customer-facing record services and the facility's purchased disposal service received different treatment. The facility did not collect tax on pickup, storage, or shredding, but it paid tax on the downstream garbage collection.

Common questions

Was document pickup taxable? No.

Were storage and certified shredding taxable? No.

Did the facility pay tax to the garbage collector? Yes.

Citations and references

The letter did not cite a rule or statute by number.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, TX 78774

BOB BULLOCK
COMPTROLLER April 19, 1988

Dear *:

Thank you for your recent letter which is restated in part with response
below.

Facts: We are a record storage facility in **, Texas. One of
the services we offer to our customers is certified destruction of
documents
and film. The documents and film are picked up from a customer or
removed
from our shelves and shredded so that they can not be identified. The
shred-
ded materials is then placed in a dumpster leased from
*****.
Once each week the dumpster is picked up and the material is disposed of
at
their dump site.

Response: Your charges for pick up, storage and shredding are not
taxable. You would pay sales to the garbage collection company on their
charges to you.

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,
Al Van Allen
Tax Policy Division

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