Ezel / Tax Rulings / TX
TX 8904L0934C01 Sales and/or Use Tax (State,Local,MTA) 1989-04-24

Were the described check-service activities taxable in Texas?

Short answer: No. Based on the submitted description and purchase agreement, Texas concluded that the client's check services were not taxable.

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This page answers the general question as of 1989. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1989
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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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

Texas concluded that the client's check-service activities were not taxable, based on the description and purchase agreement submitted with the request.

The preserved STAR text does not reproduce those underlying facts or the agreement, so the ruling does not support a broader conclusion about every check-guarantee, authorization, or purchase service.

Common questions

Were this client's described check services taxable? No.

Does the letter explain exactly how the service operated? No. It refers to a description and agreement that are not included in the STAR body.

Can the answer safely be applied to a different check-service model? Not from this record alone.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

April 24, 1989

Dear *****

Thank you for your letter regarding taxability of the check service
activities provided by your client, CORP ABC.

Based on your description of the check service and the ***
Purchase Agreement, the services provided by your client are not 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 or need more information, please call toll free
1-800-252-5555 or the regular number 512/463-4600. My extension is 3-4666.
You may write to Tax Correspondence, Comptroller of Public Accounts.

Sincerely,
Jo Ann Dieck
Tax Correspondence

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