Are telecommunications devices, signaling devices, and other assistive products for people with hearing, vision, or physical impairments exempt from New York sales tax?

Plain-English summary

LS Systems, Inc. sells a wide range of products to people with physical, hearing, and visual impairments -- telecommunications devices (TTY) and accessories, television closed-caption decoders, telephone amplifiers and answering machines, assistive listening devices, vibrating/flashing alarm clocks, hotel "guest room kits," and home signaling devices (door beacons, phone flashers, vibrating smoke detectors, and similar products) -- both directly and through retailers, hotels, and schools for the deaf. It asked whether these sales, its TTY repair services, and its own business expenses while performing repairs are subject to sales tax.

New York exempts "prosthetic aids" and "artificial devices" that replace a missing body part or function of a permanently impaired body part and aren't generally useful to people without a disability. The Department walked through each category: TTY devices, television decoders, telephone amplifiers, answering machines, and assistive listening devices all fit squarely within the Department's own regulatory examples of exempt prosthetic devices (telephone/TV sound amplification, teletype-to-voice conversion, closed-caption receivers). The clocks, guest room kits, and signaling devices also qualified, because they substitute vibration or light for a person's diminished hearing or sight and aren't generally useful to someone without a disability.

Two categories came out differently. TTY accessories are exempt only if they're clearly identifiable replacement parts for an exempt device (like manufacturer-labeled batteries) -- otherwise the buyer pays tax up front and can seek a refund later. And "supplies" used alongside an exempt device -- specifically the TTY carrying case and the printer paper used for hard-copy TTY communication -- remain taxable, because supplies (as opposed to component parts) don't share the exemption. Shipping charges are taxable only when the underlying sale is taxable, and destination controls: shipments to addresses outside New York aren't subject to New York tax at all. Repair services on the exempt devices are also exempt. Sales to certified exempt organizations or to retailers with a resale certificate avoid tax entirely, and Petitioner's own purchases of business expenses (gas, meals, lodging) while performing repairs are ordinary taxable purchases unless Petitioner itself qualifies as an exempt organization.

What this means for you

Assistive-technology and adaptive-equipment retailers

Products that substitute for a missing sense or bodily function -- hearing, vision, or communication -- and that aren't generally useful to someone without a disability are very likely exempt prosthetic aids or artificial devices, even when they look like ordinary consumer electronics (an amplified phone, a flashing alarm clock, a vibrating pager). But keep "supplies" (carrying cases, paper, batteries that aren't clearly labeled as device-specific) and unidentified accessory parts separate on your invoices, because those stay taxable by default.

Businesses shipping exempt medical/assistive products

Shipping charges are only taxed when the sale itself is taxed, and New York's destination-based sourcing rule means a shipment delivered outside New York isn't subject to New York tax at all, regardless of where the seller is located.

Accountants and tax professionals

This opinion is a useful checklist against 20 NYCRR § 528.5's regulatory examples (sound amplification, teletype conversion, closed-caption reception) for classifying new-to-market assistive products. Note the separate-statement rule for combination products: if a device is sold with an added special feature for a disabled user (e.g., an amplifier built into an ordinary phone), the whole item is taxable unless the added-feature charge is separately stated, in which case only that portion is exempt.

Common questions

Q: Are hearing aids, TTY devices, and closed-caption decoders exempt from New York sales tax?
A: Yes, they qualify as exempt prosthetic aids or artificial devices under Tax Law § 1115(a)(4) because they replace or restore a lost sensory function and aren't generally useful without a disability.

Q: Are repair services on these devices taxable?
A: No -- repair, maintenance, and installation services are exempt when performed on a device whose sale is itself exempt as a prosthetic aid.

Q: Are carrying cases and printer paper sold with a TTY device taxable?
A: Yes -- these are "supplies" used in conjunction with an exempt device, not component parts of the device itself, so they remain taxable when delivered in New York.

Q: What if a product is shipped to a customer outside New York?
A: New York sales tax doesn't apply to sales delivered outside the state, since the tax follows the point of delivery.

Citations and references

Statutes and regulations:

• Tax Law § 1101(b)(3) (definition of "receipt")
• Tax Law § 1105(a), (c)(3) (imposition of sales tax; repair/installation services)
• Tax Law § 1115(a)(3) (medical equipment and supplies exemption)
• Tax Law § 1115(a)(4) (prosthetic aids, hearing aids, artificial devices exemption)
• Tax Law § 1115(g) (exemption for repair services on exempt items)
• 20 NYCRR § 525.2(a)(3) (destination test)
• 20 NYCRR § 526.5(g) (shipping and delivery charges)
• 20 NYCRR § 528.4(e) (medical equipment)
• 20 NYCRR § 528.5 (prosthetic aids, hearing aids, artificial devices)

Source

• Landing page: https://www.tax.ny.gov/pubs_and_bulls/advisory_opinions/sales_ao_1999.htm
• Opinion: https://www.tax.ny.gov/pdf/advisory_opinions/sales/a99_11s.pdf

Original ruling text

New York State Department of Taxation and Finance

Taxpayer Services Division
Technical Services Bureau

TSB-A-99(11)S
Sales Tax
March 1, 1999

STATE OF NEW YORK
COMMISSIONER OF TAXATION AND FINANCE
ADVISORY OPINION

PETITION NO. S980513A

On May 13, 1998, the Department of Taxation and Finance received a Petition for Advisory
Opinion from LS Systems, Inc., 1200 Jefferson Road, Rochester, NY 14623. Petitioner, LS
Systems, Inc., provided additional information pertaining to the petition on June 10, 1998 and
November 30, 1998.
The issues raised by Petitioner are:
(1) Whether receipts from its sales of the below listed products, including shipping charges
for deliveries within and without New York State, to individuals with physical, hearing and
visual impairments are subject to sales tax.
(2) Whether receipts from its sales of repair services performed on telecommunications
devices (TTY) are subject to sales tax.
(3) Whether expenses it incurs in the performance of such repair services such as gas, meals
and lodging can be purchased without payment of sales tax.
Petitioner submitted the following categorized list of its products and provided a brief
description of their functions. Petitioner sells its products to individuals with physical, hearing and
visual impairments, both directly and through retailers which include stores, hotels and schools for
the deaf.
A)

TELECOMMUNICATION DEVICES (TTY) AND ACCESSORIES
1.

Devices - used in conjunction with conventional telephones and computers to enable
a hearing/visually impaired person to communicate by these methods.
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Uniphone 1000
Uniphone 1140
EzPro Com
Miniprint 225
Miniprint 425
Superprint 4425
Superprint 4425 w/Ascii
Superprint 4225 w/o direct conn

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Accessories for TTY Devices
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B)

Minicom IV
Superprint 4400 Ascii w/o printer
Superprint 4400 /Ascii
Compact
Compact Ascii
External TTY modem
Shelf pay phone
Motorized pay phone
Internal TTY modem
Superpro 80

Switchskins (clear protective covering)
Printer paper
Large visual display (used by the visually impaired)
AC adaptor (replacement battery)
TTY dust cover
TTY carrying case

ASSISTIVE TECHNOLOGY
1.

Television Decoders - devices installed in televisions built before 1993 which are
used for receiving closed captioned TV programs.
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2.

Junior caption decoder
Decoder 100
Mycap Supervision

Telephone Amplifiers - devices which clarify or amplify sound.
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Amplified phone w/clarity cont.
Voice carry over phone
Cordless amplified phone
Portable telephone amplifier
Handset amplifier
Amplifier receiver handset
Hearing aid compatible handset

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3.

Telephone Answering Machines - designed to relay telephone calls so messages can
be retrieved by hearing impaired individuals through telecommunications devices
(TTY).
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4.

Assistive Listening Devices - used to transmit sound directly from various sources
(e.g., from a TV or a speaker in a classroom setting) to a hearing aid so that a
hearing impaired individual hears only that sound and no outside noise.
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5.

Powerphone
Answerall Model 100

Vibrating vest for sound
Pockettalkers
Direct set
Audioport
HF megaear
Sound wizard listening system
Chorus universal listening system
Infared conference microscop
Companion FM system
Microloop system
Personal FM system
Personal FM education system

Clocks - time measuring devices with alarms which work by means of light or
vibration.
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Global access
Lil Ben vibrator
Vibrasound clock (sold separately)
Vibrator (sold separately)
Halhen Clock
Halhen vibrator
Halhen strobe
Vibralite wristwatch
Microvibrate pocketwatch
Shakeawake
Sonic boom clock

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6.

Guest room kits - kits containing devices that are required by the Americans with
Disabilities Act to be available in every hotel room rented by persons with
disabilities.
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C)

Guestroom Kit - contains such items as flashing door alarms,
phone ringer signals and closed caption devices for the TV.
Guest kit w/o smoke/decoder
Alert Master (door/phone alarms)
Alert Master plus accessory - includes the baby crier option
and two-bed receiver.

SIGNALING DEVICES - home automation devices (or parts of such) modified to convey
some form of notice or warning to handicapped individuals by transmitting signals to one
of three basic types of receivers; lamps, vibrators or strobe lights. All items on this list have
been adapted for use by the handicapped by the addition of special parts or attachments.
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Door beacon
Knock sensor
Mini strobe light
Strobe/door chime
Phone flasher plug in
Ring/flash phone plug in
Phone strobe flasher
Phone flasher w/transmitter
Phone flasher w/transmitter, switch
Phone flasher w/o transmitter
Doorbell system w/chime
Doorbell system w/o chime
Magnetic switch - attaches to a doorbell to alert the individual
when someone enters without ringing the bell.
Telephone system
Mini timer
Smoke detector hardwired
Smoke detector hardwired w/transmitter
Smoke detector w/ plug in cord
Smoke detector w/plug w/transmitter
Smoke w/o strobe transmit
Sonic alert baby cry
Sonic receiver 101
Sonic receiver 201
Baby cry alerter

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Key chain remote - allows a visually impaired individual to
transmit a signal which turns on the lamp upon entering.
Carbon monoxide system
Motion detector
Lamp module
Appliance module
Chime module
Screw-in-lamp module - used for parts of the house that don’t
have lamps, such as the bathroom.
Split receptacle
Wall switch - replaces the conventional wall switch so
numerous receiver lamps are not needed all over the house.
Dimmer switch - same as above only dims the light.
Mini control center - allows the programming of different
lights.
Wireless telephone jack - provides for use of the TTY in
rooms where there is no phone line.
Button pager one way - a portable device which a
handicapped individual can carry to transmit sound from a
room they wish to monitor, such as a baby’s bedroom.
WP one way pager
WP two way pager
Sound activated pager

Applicable Law and Regulations
Section 1101(b) of the Tax Law states, in part:
When used in this article for the purposes of the taxes imposed by
subdivisions (a), (b), (c) and (d) of section eleven hundred five and by section eleven
hundred ten, the following terms shall mean:
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*

(3) Receipt. The amount of the sale price of any property and the charge for
any service taxable under this article, valued in money, whether received in money
or otherwise, including any amount for which credit is allowed by the vendor to the
purchaser, without any deduction for expenses or early payment discounts and also
including any charges by the vendor to the purchaser for shipping or delivery
regardless of whether such charges are separately stated in the written contract, if
any, or on the bill rendered to such purchaser and regardless of whether such

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shipping or delivery is provided by such vendor or a third party. . . . (Emphasis
added)
Section 1105 of the Tax Law states, in part:
Imposition of sales tax.-- . . . there is hereby imposed and there shall be paid
a tax of four percent upon:
(a) The receipts from every retail sale of tangible personal property, except
as otherwise provided in this article.
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(c) The receipts from every sale, except for resale, of the following services:
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(3) Installing tangible personal property . . . or maintaining, servicing or
repairing tangible personal property . . . not held for sale in the regular course of
business, whether or not the services are performed directly or by means of coinoperated equipment or by any other means, and whether or not any tangible personal
property is transferred in conjunction therewith. . . .
Section 1115 of the Tax Law provides, in part:
(a) Receipts from the following shall be exempt from the tax on retail sales
imposed under subdivision (a) of section eleven hundred five and the compensating
use tax imposed under section eleven hundred ten:
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(3) Drugs and medicines intended for use, internally or externally, in the cure,
mitigation, treatment or prevention of illnesses or diseases in human beings, medical
equipment (including component parts thereof) and supplies required for such use
or to correct or alleviate physical incapacity, and products consumed by humans for
the preservation of health but not including . . . medical equipment (including
component parts thereof) and supplies, other than such drugs and medicines,
purchased at retail for use in performing medical and similar services for
compensation.

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(4) Prosthetic aids, hearing aids, eyeglasses and artificial devices and
component parts thereof purchased to correct or alleviate physical incapacity in
human beings. (Emphasis added)
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(g) Services otherwise taxable under paragraph (3) of subdivision (c) of
section eleven hundred five shall be exempt from tax (1) if performed upon
prosthetic aids, hearing aids, eyeglasses, artificial devices or medical equipment
when receipts from the retail sale of such items are exempt from tax under the
provisions of paragraphs three and four of subdivision (a) of this section. . . .
Section 525.2(a)(3) of the Sales and Use Tax Regulations provides:
The sales tax is a “destination tax,” that is, the point of delivery or point at
which possession is transferred by the vendor to the purchaser or designee controls
both the tax incident and the tax rate.
Section 526.5(g) of the Sales and Use Tax Regulations provides, in part:
Shipping or delivery. (1) Shipping or delivery charges by a vendor to its
customer for the cost of transporting tangible personal property to the customer are
part of the vendor’s receipt subject to tax where the sale of the property is subject to
tax or where taxable services were performed on the property. This is so regardless
of whether the vendor separately states such charges in a written contract or on an
invoice and regardless of whether the vendor ships or delivers the property itself or
hires a third party to ship or deliver the property. Similarly, charges by a vendor to
its customer for picking up the customer’s property upon which the vendor is to
perform taxable services are part of the vendor’s receipt from the sale of the service
subject to tax.
Section 528.4(e) of the Sales and Use Tax Regulations provides, in part:
Medical equipment. (1) Medical equipment means machinery, apparatus and
other devices (other than prosthetic aids, hearing aids, eyeglasses and artificial
devices which qualify for exemption under section 1115[a][4] of the Tax Law),
which are intended for use in the cure, mitigation, treatment or prevention of
illnesses or diseases or the correction or alleviation of physical incapacity in human
beings.

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(2) To qualify, such equipment must be primarily and customarily used for
medical purposes and not be generally useful in the absence of illness, injury or
physical incapacity.
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Example 2: A medical patient purchases an air conditioner to be used to
lower air temperature to alleviate his illness. Since an air conditioner is nonmedical
in nature, it is not exempt from the tax.
Section 528.5 of the Sales and Use Tax Regulations provides, in part:
(a) Exemption. Prosthetic aids, hearing aids, eyeglasses and artificial devices
and component parts thereof, purchased to correct or alleviate physical incapacity in
human beings are exempt from the tax.
(b) Qualifications. (1) In order to qualify as a prosthetic aid, a hearing aid,
eyeglasses or an artificial device, the property must either completely or partially
replace a missing body part or the function of a permanently inoperative or
permanently malfunctioning body part and must be primarily and customarily used
for such purposes and not be generally useful in the absence of illness, injury or
physical incapacity.
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Example 5: Sound amplification devices for hard-of-hearing people used with
telephones or television sets are exempt.
Example 6: Specialized equipment used by the hearing impaired that converts
teletype signals into telephone signals and telephone signals into teletype signals and
thus enable a hearing impaired person to communicate by telephone, are exempt.
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Example 11: Devices for installation of TV sets for receiving closed
captioned programs are exempt.
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(2) Parts, special attachments, special lettering, etc., that are added to or
attached to tangible personal property, such as appliances, so that a handicapped

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person can use them are exempt. If tangible personal property is sold with special
controls, lettering or devices, and the additional charge for the added features is
separately stated on the bill for the tangible personal property, that portion of the
sales receipts attributable to the added features is exempt. In determining whether
the extra amount charged for the special controls, lettering or devices is reasonable,
like items exclusive of the added features should be compared with the same item
with the added features.
Example 14: If a TV is sold with a closed captioned device built in, the
portion of the price attributable to the closed captioned device, if separately stated
on the bill, can be deducted from the selling price before computing the tax.
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Example 16: Calculators which contain talking devices that are intended for
the use of blind people are subject to tax. However, that portion of the price of the
calculator attributable to the talking device is exempt from tax, if separately stated
on the bill for the calculator.
(c) Replacement parts. (1) Replacement parts for prosthetic aids, hearing
aids, eyeglasses and artificial devices must be identifiable as such at the time the
retail sale is made. If the replacement parts are not identifiable parts for prosthetic
aids, the purchaser must pay the tax at the time of purchase. The purchaser may
apply to the Sales Tax Bureau for a refund of the tax paid provided he can show that
the replacement parts were used on exempt prosthetic aids.
Example 1: Batteries for hearing aids which are clearly labeled as such by the
manufacturer are exempt replacement parts.
(2) Supplies used in conjunction with prosthetic aids, hearing aids, eyeglasses
and artificial devices are not exempt from tax.
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Example 3: Paper that may be used to produce hard copy communication that
is used in conjunction with the communication devices described in example 6 of
paragraph (1) of subdivision (b) is a taxable supply.
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(d) Servicing and repairing. Receipts from installing, maintaining, servicing
and repairing prosthetic aids, hearing aids, eyeglasses and artificial devices are
exempt from the tax imposed by paragraph (3) of subdivision (c) of section 1105 of
the Tax Law, if the items upon which such services were performed are exempt. . .
Opinion
Issue 1
Section 1115(a)(3) of the Tax Law exempts medical equipment and supplies from sales and
compensating use tax, unless purchased at retail for use in performing medical and similar services
for compensation. Under Section 1115(a)(4) of the Tax Law and Section 528.5 of the Sales and Use
Tax Regulations, receipts from the sales of prosthetic aids, hearing aids, eyeglasses and artificial
devices (and component parts thereof) purchased to correct or alleviate physical incapacity in human
beings are exempt from sales tax, even when purchased at retail by providers of medical services.
In order to qualify as a prosthetic aid, hearing aid or an artificial device, the property must either
completely or partially replace a missing body part or the function of a permanently inoperative or
permanently malfunctioning body part and must be primarily and customarily used for such
purposes and not be generally useful in the absence of illness, injury or physical incapacity.
Examples 5, 6, and 11 of Section 528.5(b) of the Sales and Use Tax Regulations provide that devices
used by hearing impaired people which provide for telephone and television sound amplification,
telecommunications, and the receiving of closed captioned TV programs constitute prosthetic
devices. Accordingly, Petitioner’s products listed under categories A)1, telecommunication devices,
B)1, television decoders, B)2, telephone amplifiers B)3, telephone answering machines and B)4,
assistive listening devices qualify as prosthetic aids or artificial devices as defined by Section
528.5(b)(1) of the Sales and Use Tax Regulations and are exempt from sales and use taxes pursuant
to Section 1115(a)(4) of the Tax Law (see Publication 822, Taxable Status of Medical Equipment
and Supplies, Prosthetic Devices and Related Items, (7/87); Brian Dee, DBA Edgerton Electronics,
Adv Op St Tx Comm, November 24, 1982, TSB-A-82(41)S).
Petitioner’s products listed under categories B)5, clocks, B)6, guest room kits and C)
signaling devices, substitute their ability to convey some form of notice or warning (through the use
of vibrators and flashing lights) to handicapped individuals for some of their lost ability to see or
hear. Moreover, they are primarily and customarily used for such purposes and are not generally
useful in the absence of illness, injury or physical incapacity. Therefore, the products listed in these
three categories also qualify as prosthetic devices exempt from the sales and compensating use taxes
under Section 1115(a)(4) of the Tax Law.
With regard to all of the above products, in the case of an item sold with special feature(s)
added so that a handicapped person may use it, such as a conventional telephone to which an
amplifier has been added for use by a hearing impaired individual, the entire charge for the item is

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taxable unless the additional charge for the special feature(s) is separately stated on the bill to the
customer. If separately stated, that portion of the sales receipts attributable to the added feature(s)
is exempt. See Section 528.5(b)(2) of the Sales and Use Tax Regulations.
As to the taxability of the items listed in category A)2, accessories for TTY devices, only
such parts that are clearly identifiable as replacement parts for exempt prosthetic aids at the time the
retail sale is made are exempt from tax, e.g., batteries for telecommunications devices which are
clearly labeled as such by the manufacturer. If the replacement parts are not identifiable parts for
prosthetic aids, the purchaser must pay the tax at the time of purchase and may apply for a refund
of the tax paid if it can be shown that the replacement parts were used on exempt prosthetic aids.
See Section 528.5(c)(1) of the Sales and Use Tax Regulations. The switchskins, large visual display
and TTY dust cover, provided they are attached to the TTY, are component parts of the prosthetic
devices and are also exempt from sales and use taxes under Section 1115(a)(4) of the Tax Law.
However, supplies used in conjunction with prosthetic aids are not exempt from tax. The TTY
carrying case and the printer paper used to produce hard copy communication that is used in
conjunction with telecommunications devices are taxable supplies where delivery occurs in New
York State. See Section 528.5(c)(2) of the Sales and Use Tax Regulations. Conversely, when
delivery is made to an address outside of New York State, the sale is deemed to take place at such
point of delivery and no New York sales tax would be imposed. See Section 525.2(a)(3) of the Sales
and Use Tax Regulations.
All shipping charges incurred by Petitioner and included in the charges to its customers are
included in the definition of “receipt” provided in Section 1101(b)(3) of the Tax Law. Therefore,
the charge to a customer for shipping is subject to tax only when the receipt from Petitioner’s sale
is subject to tax. When Petitioner makes a nontaxable sale, the amount charged to its customers,
including shipping, is not subject to tax.
It is noted that if Petitioner’s sales are to an organization exempt under Section 1116(a) of
the Tax Law, then no sales or compensating use tax will be due, provided that Petitioner obtains the
Exempt Organization Certification (ST-119.1) or other appropriate exemption document from the
purchaser within 90 days of the date of sale. See Part 529 of the Sales and Use Tax Regulations for
rules respecting exempt organizations. If Petitioner’s sales are to a retailer for resale, then no sales
or compensating use tax will be due if Petitioner obtains a resale certificate (Form ST-120) within
90 days of the date of sale. See Section 1132(c) of the Tax Law and Section 532.4 of the Sales and
Use Tax Regulations.
Issue 2
Section 1115(g) of the Tax Law provides that repair services to tangible personal property
otherwise taxable under Section 1105(c)(3) of the Tax Law are exempt from sales tax if performed
upon prosthetic aids or artificial devices when receipts from the sale of such items are exempt from

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tax under the provisions of Section 1115(a)(4). Since receipts from the sale of telecommunications
devices are exempt from tax under the provisions of Section 1115(a)(4) of the Tax Law, receipts
from Petitioner’s repair services to such devices are not subject to sales and compensating use taxes.
Issue 3
The sales tax is imposed on the receipts, unless otherwise exempt, from every retail sale of
tangible personal property and sales of specifically enumerated services, from the sale of restaurant
meals and from charges for hotel occupancy. See Section 525.2 of the Sales and Use Tax
Regulations. Therefore, unless Petitioner qualifies as an exempt organization under Section 1116(a)
of the Tax Law and has established its exempt status with the Technical Services Bureau, or makes
the purchases in question as agent for an exempt organization, its purchase of business expense
items such as gas, meals and lodging are subject to tax under Section 1105 of the Tax Law.

DATED: March 1, 1999

NOTE:

/s/
John W. Bartlett
Deputy Director
Technical Services Bureau

The opinions expressed in Advisory Opinions are
limited to the facts set forth therein.