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TX 8409L0590B03 Sales and/or Use Tax (State,Local,MTA) 1984-09-25

Did Texas require colleges and universities to collect tax on student and faculty parking permits and fees in 1984?

Short answer: No. On September 25, 1984, Comptroller Bob Bullock reversed an earlier September 17 instruction and said colleges and universities did not need to collect tax on student and faculty parking permits and fees.

Apply this to your situation

This page answers the general question as of 1984. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1984
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 general September 1984 guidance signed by the Texas Comptroller of Public Accounts, not a taxpayer-specific private letter ruling. It does not carry letter-ruling reliance protection under 34 Tex. Admin. Code Rules 3.1 and 3.10. The source contains both a September 25 reversal and the superseded September 17 instruction it replaced; this page treats the later letter as controlling within the document. Current college, university, student, faculty, staff, parking-permit, local-tax, and exemption rules may differ, and STAR documents may no longer represent current policy even when not marked superseded. 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

On September 25, 1984, Texas Comptroller Bob Bullock reversed an earlier instruction and said colleges and universities did not need to collect tax on student and faculty parking permits and fees.

The same STAR document includes the superseded September 17 letter, which had said that motor-vehicle parking and storage fees would become taxable October 2 and directed colleges and universities to begin collecting tax on student and faculty parking permits and fees. The later letter expressly says the Comptroller reconsidered that application of the new tax-code provision.

What this means for you

Colleges and universities

Within this document, the September 25 reversal controls over the embedded September 17 instruction.

Accountants and tax professionals

This is broad historical guidance, not a taxpayer-specific ruling. Verify current higher-education parking and local-tax rules.

Common questions

Q: Did colleges and universities have to tax student and faculty parking under the final letter?
A: No.

Q: Why does the source also say the fees were taxable?
A: It reproduces the earlier September 17 instruction that the September 25 letter reversed.

Q: Did the reversal mention staff parking?
A: The body says student and faculty parking; “staff” appears in STAR metadata but not in the operative reversal.

Citations and references

  • The letters refer to a new tax-code provision and legislative act but do not identify either by number.

Source

Original ruling text

September 25, 1984

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Dear

Recently you received a letter from my office advising you that
colleges and universities would be required to collect tax on all
student and faculty parking permits and fees.

After reconsidering the application of the new tax code provision to
these fees, I have concluded that colleges and universities need not
collect tax on them.

I sincerely hope the earlier letter did not cause you any
inconvenience.

Sincerely,

BOB BULLOCK
Comptroller of Public Accounts

September 17, 1984

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Dear

Effective October 2, motor vehicle parking and storage fees come under
state and local taxes for the first time ever.

THIS IS A RESULT OF AN ACT BY THE TEXAS LEGISLATURE.

You must begin collecting the tax on October 2 on all permits and fees
for student and faculty parking privileges. Tax is not due on permits
sold or fees collected before October 2 even though parking privileges
extend past October 1.

Please have your business office report the tax along with any other
sales taxes you may now collect, such as those on book or food sales.
If your college or university does not have a sales tax permit, you
must get one.

If you need more information, you may contact one of our field service
offices on the enclosed list or call 1-800-252-5555 toll free from
anywhere in Texas.

Sincerely,

BOB BULLOCK
Comptroller of Public Accounts

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