TX 9004L0996G13 Sales and/or Use Tax (State,Local,MTA) 1990-04-05

Was a separately stated coin-wrapping charge taxable when a company transported bulk coin to its facility and wrapped it there?

Short answer: No. Coin wrapping performed by the company's personnel at its facility was not subject to sales tax when the charge was separately stated from charges for taxable services.

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This page answers the general question as of 1990. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1990
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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 company transported bulk coin to its own facility, where its personnel wrapped the coin. It did not perform the wrapping in its trucks.

The Comptroller ruled that the coin-wrapping service was not subject to sales tax when its charge was separately stated from charges for taxable services.

Common questions

Was coin wrapping taxable? No, under the facts described.

What documentation mattered? The coin-wrapping charge had to be separately stated from taxable service charges.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

April 5, 1990




Dear ***:

I just want to take a minute to respond to your FAX
transmission on coin-wrapping services.

In our follow-up phone conversation, you confirmed that
CORP A does not do coin wrapping in their trucks but rather
transports bulk coin to their facilities where they
are wrapped by CORP A personnel. Coin-wrapping services,
including this type, are not subject to sales tax when
separately stated from charges for taxable services.

I hope this information proves helpful. Feel free to call or
write me if you have questions. You can reach me by calling
toll free 800-531-5441 or FAX (512) 475-0900.

Sincerely,
Al Van Allen
Taxability Section
Legal Services Division

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