Are the coin-operated fees a laundromat charges customers to wash their own dogs in a self-service dog-wash machine subject to New York sales tax?

Plain-English summary

Robo Enterprises, Inc. built a laundromat in Jamestown, NY that includes a coin-operated, self-service dog washing station: customers walk their dog into a waist-high tub, insert money for a set number of minutes, choose a wash setting, rinse, and use an attached blow dryer — all without any help from Robo's employees.

The Department's answer turns on a regulatory definition that surprises most people: New York's sales tax regulations expressly list animals as a category of "tangible personal property" (alongside trees, shrubs, plants, and seeds). Since a dog counts as tangible personal property for sales-tax purposes, washing and drying it is treated the same as washing any other item of tangible personal property — a taxable service of "maintaining, servicing or repairing tangible personal property" under § 1105(c)(3), which helps keep the "property" (the dog) in "a condition of fitness." The statute explicitly covers services performed by coin-operated equipment, so the lack of any employee involvement doesn't matter — the coin-operated dog wash's receipts are subject to sales tax just like a coin-operated car wash or a coin-operated laundry dry-cleaning machine would be.

What this means for you

Laundromat and self-service business owners

If you're adding a coin-operated pet-washing station (or any similar self-service equipment that "services" an item — vacuum, wash, polish, etc.), expect the receipts to be taxable maintaining/servicing revenue, regardless of whether it's staffed. Build sales tax collection into your coin-operated pricing and reporting from the start.

Pet service and grooming businesses

This ruling is a useful (if unusual) confirmation that animal-washing services are squarely inside New York's taxable "maintaining tangible personal property" category — the same category traditional pet grooming and pet washing services generally fall into, coin-operated or not.

Accountants advising retail/service clients

Watch for other unconventional applications of the "animals = tangible personal property" regulatory definition when reviewing a client's coin-operated or self-service equipment offerings — the underlying rule (§ 1105(c)(3) covers coin-operated servicing) applies broadly, not just to dog washing.

Common questions

Q: Are dogs really considered "tangible personal property" for New York sales tax purposes?
A: Yes — New York's sales tax regulations specifically list animals as a category of tangible personal property, which is why services performed on them (like washing) can be taxed the same way services on any other personal property would be.

Q: Does it matter that no employee helps with the coin-operated wash?
A: No. The statute taxing installing/maintaining/servicing tangible personal property explicitly applies whether the service is performed directly by an employee, by coin-operated equipment, or by any other means.

Q: Would a full-service (staffed) dog grooming/washing business be taxed the same way?
A: This opinion addresses the coin-operated, self-service model specifically, but the underlying legal theory — washing a dog is "maintaining/servicing tangible personal property" — would generally extend to staffed pet-washing services too.

Q: Does this ruling apply to any coin-operated pet-service business?
A: This is a fact-specific Advisory Opinion binding only on Robo Enterprises, Inc. and its described facility, but its reasoning (animals as tangible personal property; coin-operated servicing is still taxable servicing) is a clear and generally applicable statement of the underlying rule.

Citations and references

• Tax Law § 1105(c)(3) (installing, maintaining, servicing, or repairing tangible personal property, including via coin-operated equipment)
• 20 NYCRR § 526.8(a)(4) (tangible personal property; includes animals, trees, shrubs, plants, and seeds)
• 20 NYCRR § 527.5(a)(3) (maintaining, servicing, repairing definitions)

Source

• Landing page: https://www.tax.ny.gov/pubs_and_bulls/advisory_opinions/sales_ao_2008.htm
• Opinion: https://www.tax.ny.gov/pdf/advisory_opinions/sales/a08_17s.pdf

Original ruling text

New York State Department of Taxation and Finance
TSB-A-08(17)S
Sales Tax
March 19, 2008

Office of Tax Policy Analysis
Taxpayer Guidance Division
STATE OF NEW YORK
COMMISSIONER OF TAXATION AND FINANCE
ADVISORY OPINION

PETITION NO. S071126B

On November 26, 2007, the Department of Taxation and Finance received a Petition for
Advisory Opinion from Robo Enterprises, Inc., 1310 East Second Street, P.O. Box 940,
Jamestown, NY, 14702-0940.
The issue raised by Petitioner, Robo Enterprises, Inc., is whether receipts from a
coin-operated dog washing machine are subject to sales tax.
Petitioner submitted the following facts as the basis for this Advisory Opinion.
Petitioner has recently constructed a laundromat facility located in Jamestown, NY. Part
of the facility consists of a coin-operated dog washing machine with an attached tub. A
customer wishing to use the dog washing machine would bring in the dog, place it in a tub basin
and tether the animal. The customer would insert the appropriate amount of money into the
machine. The customer would then proceed to wash and dry the dog. There is no assistance or
intervention in the process on the part of any of Petitioner's employees. A recent news article
from The Post-Journal of Jamestown described Petitioner's dog washing facility as follows:
When you enter the dogwash center, the exhaust fan immediately turns on. Then you can
walk Snoopy up the ramp into the sink basin. Put $5 in the slot (for 8 minutes of wash
time), [and] choose which of the several settings you would like to start with.
The sink is waist-high so you aren’t bending over as is customary when washing a dog in
the bathtub. Once you’ve rinsed your pet, switch the knob once more to take advantage
of the blow dryer. Ideally, you will have a clean and dry dog when you walk out with no
mess at home to clean up.1
Applicable law and regulations
Section 1105 of the Tax Law provides, in part, that the sales tax is imposed upon:
(c) The receipts from every sale, except for resale, of the following services:
*
*
*
(3) Installing tangible personal property, excluding a mobile home, or
maintaining, servicing or repairing tangible personal property, including a mobile home,
not held for sale in the regular course of business, whether or not the services are
performed directly or by means of coin-operated equipment or by any other means, and
whether or not any tangible personal property is transferred in conjunction therewith, . . .
1

Rizzuto, Jamestown Business Diversifies Offerings, The Post-Journal, January 3, 2008

-2­
TSB-A-08(17)S
Sales Tax
March 19, 2008

Section 526.8(a) of the Sales and Use Tax Regulations (Regulations) provides, in part:
Definition. The term tangible personal property means corporeal personal
property of any nature having a material existence and perceptibility to the human senses.
Tangible personal property includes, without limitation:
*

*

*

(4) Animals, trees, shrubs, plants and seeds; (emphasis added)
Section 527.5(a)(3) of the Regulations provides, in part:
Maintaining, servicing and repairing are terms used to cover all activities that
relate to keeping tangible personal property in a condition of fitness, efficiency, readiness
or safety or restoring it to such condition.
Opinion
Petitioner's newly constructed laundromat facility is also equipped with a coin-operated
dog washing machine. Customers use the dog washing machine to wash and dry their dogs
without the assistance of any of Petitioner's employees. Pursuant to section 526.8(a)(4) of the
Regulations, dogs are considered to be tangible personal property for purposes of the sales tax.
Washing a dog using a coin-operated machine qualifies as maintaining tangible personal
property under section 1105(c)(3) of the Tax Law and section 527.5(a) of the Regulations as
such action helps keep the dog in a condition of fitness. Therefore, the receipts from Petitioner's
coin-operated dog washing machine are subject to sales tax under section 1105(c)(3).

DATED: March 19, 2008

NOTE:

/s/
Jonathan Pessen
Tax Regulations Specialist IV
Taxpayer Guidance Division

An Advisory Opinion is issued at the request of a person or entity. It is
limited to the facts set forth therein and is binding on the Department only
with respect to the person or entity to whom it is issued and only if the
person or entity fully and accurately describes all relevant facts. An
Advisory Opinion is based on the law, regulations, and Department
policies in effect as of the date the Opinion is issued or for the specific
time period at issue in the Opinion.