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Ezel / Tax Rulings / TX
TX 8211L0711E08 Motor Vehicle Tax 1982-11-16

Could a vehicle operator satisfy Texas reciprocity use-tax duties by offering records for audit instead of filing Form 14-112?

Short answer: No. Section 152.043 required use tax on qualifying reciprocity-agreement vehicles by the day they entered Texas. Form 14-112 identified the tax and vehicles being paid. As an administrative accommodation, Texas allowed one quarterly filing for all vehicles used during the quarter. Merely allowing the Comptroller to inspect records later did not satisfy payment; the form was filed when tax was due, not as a regular no-tax report.

Apply this to your situation

This page answers the general question as of 1982. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1982
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 1982 Texas Comptroller taxpayer-response letter applying § 152.043 and historical registration-fee reciprocity agreements. Form 14-112, the State Department of Highways and Public Transportation, entry-day due date, quarterly accommodation, and non-IRP terminology may be obsolete or replaced. The letter distinguishes a tax-due remittance form from a regular report. STAR documents may no longer represent current policy even when not marked superseded. Taxpayer 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

Offering books and records for later examination did not satisfy the duty to pay use tax on reciprocity-agreement vehicles.

Section 152.043 made tax payable by the day the vehicle entered Texas. Form 14-112 identified the tax and vehicles. Texas allowed consolidated quarterly filing instead of separate remittance each time a vehicle entered.

The form was filed only when tax was due; it was not a regular no-tax report.

What this means for you

Record availability is not the same as timely remittance. Follow the applicable payment and vehicle-identification process.

Common questions

Q: Was quarterly filing allowed?
A: Yes, as an administrative accommodation.

Q: Did an audit right replace filing?
A: No.

Citations and references

  • Texas Tax Code § 152.043 — historical reciprocity vehicle use-tax provision
  • Form 14-112 — historical remittance form

Source

Original ruling text

November 16, 1982

Dear ***:

Thank you for your letter of October 28, regarding the legality of our
requiring the completion of Form 14-112.

Texas Tax Code Ann. Sec. 152.043 provides that the use tax imposed on
vehicles operated under agreements entered into by the State Department
of Highways and Public Transportation for the registration fees shall
be paid to the Comptroller on or before the day the motor vehicle is
brought into Texas.

Form 14-112 was designed so that operators of motor vehicles wishing
to comply with the law and pay the tax as imposed, could remit the tax
and designate what tax is being paid and on which vehicles it is being
paid.

For ease of administration we allow the form to be filed once each
quarter to remit tax on any vehicles used in Texas during the quarter,
rather than requiring separate remittances as each vehicle enters
Texas on any particular day.

Merely allowing the Comptroller to inspect books and records, to
determine what tax is due, does not comply with the law. The form
itself is not one required to be filed as a regular report but only to
be filed when tax is due.

If you have any further questions or comments please write or call.

Sincerely,

Motor Vehicle Tax Division

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