Ezel / Tax Rulings / TX
TX 9810866L Motor Vehicle Tax 1998-10-09

Did a licensed Texas emergency shelter qualify for the residential child-care motor vehicle sales tax exemption?

Short answer: Yes. The Texas Department of Protective and Regulatory Services said a licensed emergency shelter qualified under the Human Resources Code to provide the described 24-hour residential care. The facility produced its agency license showing it was a permitted emergency shelter, so the Comptroller approved the exemption.

Apply this to your situation

This page answers the general question as of 1998. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1998
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 to a specific licensed facility. It dates from 1998, predates modern Private Letter Ruling reliance terms, and cannot be treated by unrelated organizations as binding protection. Agency names, licensing categories, Human Resources Code requirements, and exemption rules may have changed, so verify current licensing and tax law. 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

The Texas Comptroller approved a motor vehicle sales tax exemption for a facility licensed as a permitted emergency shelter.

The Texas Department of Protective and Regulatory Services told the Comptroller that a licensed emergency shelter qualified under the Human Resources Code to provide 24-hour residential care to children who did not require specialized services or treatment and to emotionally disturbed children living together.

The facility supplied a copy of its agency license showing that it operated a permitted emergency shelter. That documented status supported the exemption.

What this means for you

Emergency shelters and residential child-care facilities

The historical result depended on the facility's specific child-care license and qualifying residential-care status.

Nonprofit accountants and fleet managers

Keep the current license and agency documentation supporting the claimed exemption.

Common questions

Q: Did the shelter qualify?

A: Yes.

Q: What proof did it provide?

A: A copy of the state agency license showing it was a permitted emergency shelter.

Q: What care did the agency say the license covered?

A: The described 24-hour residential care for children.

Citations and references

  • Texas Human Resources Code; the letter did not identify a section number.

Source

Original ruling text

October 9, 1998

Dear Mr. **:

Thank you for your letter concerning the THE CENTER exemption from motor
vehicle sales tax.

The Texas Department of Protective and Regulatory Services has indicated that a
facility licensed as an emergency shelter is qualified under the Human
Resources Code to provide 24 hour residential care to children who do not
require specialized services or treatment and children who are emotionally
disturbed living together.

You have provided a copy of the Texas Department of Protective and Regulatory
Services license indicating that the THE CENTER operating the EMERGENCY SHELTER
is a permitted emergency shelter and will thus qualify for the motor vehicle
sales tax exemption.

If you have any questions please contact one of our Tax Specialist by calling
1-800-252-1382, toll free.

Sincerely,

Curt Swenson
Tax Policy Division

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