Ezel / Tax Rulings / TX
TX 9101L1069C05 Sales and/or Use Tax (State,Local,MTA) 1991-01-28

Are reduced campground fees for storing unoccupied camping trailers and recreational vehicles subject to Texas sales tax?

Short answer: Yes. Texas treated the charges as taxable storage of an unoccupied trailer or recreational vehicle, even when the vehicle remained at a campsite.

Apply this to your situation

This page answers the general question as of 1991. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1991
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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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

A campground operator charged reduced fees when customers left camping trailers and similar recreational vehicles in campsites.

The Comptroller said the charges were subject to sales tax when the trailers or recreational vehicles were unoccupied. The location did not change the result: keeping the vehicle at a campsite instead of in a storage yard was still storing it for its owner.

What this means for you

A campground cannot avoid the tax treatment described in this letter merely by storing an unoccupied trailer or recreational vehicle in a campsite. The letter focuses on the storage function, not whether the property sits in a conventional storage yard.

Common questions

Were the reduced storage charges taxable? Yes.

Did it matter that the vehicle remained in a campsite? No. The Comptroller said the issue was that an unoccupied vehicle was stored for its owner.

Did the letter address fees while guests occupied the vehicles? No. Its conclusion expressly concerned unoccupied trailers and recreational vehicles.

Citations and references

The letter did not cite a statute or administrative rule.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

January 28, 1991

Dear ****:

I'd like to commend Dot Burchard's letter of September 20, 1985. You had
asked about charges for allowing folks to leave camping trailers and similar
vehicles in your campsites at a reduced rate.

Charges by campground operators for storing unoccupied trailers and
recreational vehicles are subject to sales tax. The issue is not one of
keeping the item at a campsite as opposed to having it in a storage yard but
rather the fact that an unoccupied vehicle is stored for its owner.

If you have questions or need more information, please call our toll-free
number
1-800-531-5441. My direct line number is 512463-4680 [FAX (512)
475-0900]. You may write to me in care of Tax Administration Division.

Sincerely,
Al Van Allen
Tax Administration Division

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