Ezel / Tax Rulings / TX
TX 9703309L Motor Vehicle Tax 1997-03-12

Was Sallie Mae exempt from Texas motor vehicle sales and use tax on a vehicle purchase in 1997?

Short answer: Yes. The Comptroller said the federal exemption in 20 U.S.C.A. § 1087-2 exempted the Student Loan Marketing Association from Texas motor vehicle sales and use tax, so its Texas vehicle purchase was exempt. This entity-specific 1997 result should not be assumed current.

Apply this to your situation

This page answers the general question as of 1997. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1997
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 letter issued specifically to the Student Loan Marketing Association in 1997. It predates modern Private Letter Ruling reliance terms and cannot be treated by unrelated taxpayers as binding protection. Sallie Mae's legal status and the federal statute cited by the letter may have changed; the historical exemption should not be assumed to apply to a present-day entity or transaction. 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

The Texas Comptroller said the Student Loan Marketing Association's purchase of a motor vehicle in Texas was exempt from Texas motor vehicle sales and use tax.

The letter based that entity-specific result on the tax exemption then provided by 20 U.S.C.A. § 1087-2 and told Sallie Mae it could show the letter as proof of exemption.

Because the response dates to 1997 and concerns Sallie Mae's own status, it does not establish a current exemption for another organization or present-day transaction.

What this means for you

Exempt organizations and institutional fleet managers

The holding depended on the named entity's federal statutory exemption, not a general vehicle-purchase rule.

Motor vehicle dealers

The letter served as proof for Sallie Mae's described purchase; it did not authorize treating other buyers as exempt.

Common questions

Q: Was Sallie Mae's Texas vehicle purchase exempt in the letter?

A: Yes.

Q: What law did the Comptroller cite?

A: 20 U.S.C.A. § 1087-2.

Q: Does the letter prove Sallie Mae or another buyer is exempt today?

A: No. Current status and law must be verified.

Citations and references

  • 20 U.S.C.A. § 1087-2 — cited as the source of Sallie Mae's exemption in 1997.

Source

Original ruling text

March 12, 1997

Sallie Mae

Dear **:

Thank you for your letter regarding the exempt status for the Student Loan
Marketing Association (Sallie Mae) on the purchase of a motor vehicle.

The exemption from tax provided by Title 20 U.S.C.A., Section 1087-2, does
exempt the Student Loan Marketing Association from the Texas Motor Vehicle
Sales and Use Tax. Therefore, your association's purchase of a motor vehicle
in Texas is exempt from tax. Feel free to show this letter as proof of
exemption. My phone number is listed below for further questions or
verification.

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

If you have any questions, please do not hesitate to call me toll free at
1-800-531-5441, extension 34663. My direct number is 512/463-4663. You may
also write to Tax Policy Division, Comptroller of Public Accounts.

Sincerely,
Joan Hale
Tax Policy Division

Get today's answer for your situation

You just read a 1997 ruling on this question. Ezel checks current Texas tax law and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.