Ezel / Tax Rulings / TX
TX 9201L1152A05 Sales and/or Use Tax (State,Local,MTA) 1992-01-14

Did the amendment to Texas Tax Code § 151.3101 make sports league fees or spectator admissions taxable?

Short answer: No. The letter said neither league fees paid by individuals or teams to participate in games nor admission paid by individual spectators was taxable for the requesting organization.

Apply this to your situation

This page answers the general question as of 1992. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1992
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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 confirmed that neither league fees paid by individuals or teams to participate in games nor admissions paid by individual spectators were taxable for the requesting organization.

The recent amendment to Tax Code § 151.3101 did not change that exempt status on the facts presented.

What this means for you

The ruling addresses this organization's participation fees and spectator admissions only. Other organizations or separately sold services may have different facts.

Common questions

Were team league fees taxable? No. Were individual participation fees taxable? No. Were spectator admissions taxable? No.

Citations and references

  • Texas Tax Code § 151.3101 (amusement services)

Source

Original ruling text

January 14, 1992

Dear **:

Thank you for your letter of November 27, 1991, requesting written
verification of a verbal response that the recent amendment to Section
151.3101 of the Texas Tax Code does not affect the exempt status of
league fees or admissions charged by your organization.

Neither the league fees paid by individuals or teams to participate
in games nor admissions paid by individual spectators are taxable.

This opinion is based on the facts presented. If there are additional
or different facts, the opinion may change.

You may call toll free 1-800-252-5555 if you have any questions or
need more information. You may write to Tax Administration Division,
Comptroller of Public Accounts.

Sincerely,

Eddie C. Washington
Tax Administration Division

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