Was an oilfield company's charge for pressure testing well rods and tubing taxable under Texas Letter Ruling 9205L1171B14?
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This page answers the general question as of 1992. Ezel answers yours, under current Texas tax law, with citations.
Plain-English summary
The company's charge for testing oil-well rods and tubing was not taxable on the facts presented.
The company used a 50-barrel load-and-test truck at oilfield leases to apply pressure and determine whether rods were parted or tubing had a hole. If testing found a problem, the company contacted the well owner or representative, who arranged for a separate crew to make the repair. The testing company made no repairs itself.
What this means for you
The letter's answer was limited to diagnostic pressure testing by a company that did not perform the resulting repair work. Additional or different services could change the result.
Common questions
What was the company testing for? Parted rods and holes in tubing.
Did the company repair the well equipment? No. It notified the owner or representative, who arranged a repair crew.
Was the testing charge taxable? No under the facts presented.
Citations and references
The letter cited no specific statute or administrative rule.
Source
- STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
- Opinion: https://star.comptroller.texas.gov/view/9205L1171B14
Original ruling text
May 20, 1992
Dear ***:
Thank you for your recent letter asking about the taxability of the work
performed by your company.
Your facts: You stated that your company owns a 50 barrel load and test truck.
The truck is used in the oil field on leases to pressure up on the rods and
tubing to discover if the rods are parted or if there is a hole in the tubing.
If a repair is needed, you contact the well owner or representative who, in
turn, arranges for a crew to perform the repair. Your company makes no repairs.
Response: Your company's charge for testing to discover if the rods are parted
or if the tubes have holes is 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, you may call me toll free
at 1-800-252-5555, extension 3-4633. The regular number is 512/463-4633. You
may also write to the Tax Administration Division.
Sincerely,
Wanda Hutcheson
Tax Administration Division
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