Ezel / Tax Rulings / TX
TX 9308L1251D01 Motor Vehicle Tax 1993-08-11

Did Texas include a vehicle's unit property-tax value in the motor vehicle sales-tax base under Senate Bill 878?

Short answer: No. Comptroller John Sharp said he would interpret Senate Bill 878 according to the stated legislative intent and would not require a vehicle's unit property-tax value to be included in its sales price for motor vehicle sales-tax purposes.

Apply this to your situation

This page answers the general question as of 1993. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1993
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 a 1993 interpretive letter signed by Texas Comptroller John Sharp concerning legislative intent for Senate Bill 878, not a modern taxpayer-specific Private Letter Ruling. It does not provide individualized detrimental-reliance protection. Senate Bill 878, vehicle inventory property tax, unit-value calculations, sales-price definitions, and motor vehicle tax-base rules may have changed. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice.
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 Comptroller John Sharp said the unit property-tax value of a motor vehicle would not be included in the vehicle's sales price for motor vehicle sales-tax purposes.

The letter accepted the correspondent's explanation that Senate Bill 878 was not intended to include that value and that the final selling price had to be determined before tax could be computed.

What this means for you

Motor vehicle dealers and inventory-tax professionals

The 1993 Comptroller interpretation kept the unit property-tax value outside the motor vehicle sales-tax base.

Legislative tax staff

The letter expressly relied on stated legislative intent.

Common questions

Q: Was unit property-tax value included in sales price?

A: No.

Q: What legislation did the letter interpret?

A: Senate Bill 878.

Citations and references

  • Texas Senate Bill 878, 73rd Legislature — legislation interpreted in the letter.

Source

Original ruling text

August 11,1993

Dear ****:

Thank you for your recent letter concerning the interpretation of Senate
Bill 878 regarding the inclusion of the unit property tax value of a
motor vehicle in the motor vehicle sales tax base. In the letter, you
stated that it was not the intent of the Legislature to include
this in the tax base and that to do so would be literally impossible
because the final selling price must be determined before the tax can be
computed.

In accordance with your letter, I intend to interpret the new provision
to follow the legislative intent and will not require the unit property
tax value to be included in the sales price of the motor vehicle for
motor vehicle sales tax purposes.

I appreciate your advising me of the legislative intent.

Sincerely

JOHN SHARP
Comptroller of Public Accounts

NOTE: Previous Accession Number 9308059L.3 and/or 9308059L

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