Ezel / Tax Rulings / TX
TX 8811L0913E11 Sales and/or Use Tax (State,Local,MTA) 1988-11-17

Were labor charges for aircraft inspection estimates, resulting work, general service, repair, or remodeling taxable?

Short answer: No. Texas said the aircraft labor charges were not taxable, while materials used in repair, remodeling, maintenance, or restoration were taxable.

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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 Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. Letters on STAR can be the basis of a detrimental reliance claim only for the taxpayer to whom the letter was directly issued (see 34 Tex. Admin. Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional about your specific situation.
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 said labor charged to estimate aircraft inspections was not taxable. Labor performed as a result of those inspections and labor for general aircraft service were also not taxable.

Under Rule 3.292's aircraft provisions, labor for repair, remodeling, maintenance, and restoration was not taxable, but the materials were taxable.

Common questions

Was inspection-estimate labor taxable? No.

Was labor resulting from the inspection taxable? No.

What part was taxable? Materials used in the aircraft work.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS

STATE OF TEXAS

AUSTIN, 78774

BOB BULLOCK

Comptroller

November 17, 1988

Dear ***:

We received your letter questioning the taxability of certain

labor charges, which result from aviation services. The labor

charge to provide estimates of aircraft inspections is not

taxable. Likewise, labor performed as a result of these inspec-

tions is also not taxable. In addition, labor charges to provide

general service to aircraft is not taxable.

Enclosed is a copy of Rule 3.292 entitled Repair, Remodeling,

Maintenance and Restoration of Tangible Personal Property.

Section (b)(1)(A) and (b)(2)(A) refer to the repair, remodeling

etc., of aircraft. In both instances the labor is not taxable,

but the materials are taxable.

This opinion is based on the facts presented. If there are

additional or different facts, the opinion may change.

If you have any questions, please contact Tax Correspondence. You

may call toll free 1-800-252-5555, or our regular number is 512/

463-4600. My extension is 3-4658.

Sincerely,

Sherry Buckley

Tax Correspondence

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