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Ezel / Tax Rulings / TX
TX 8409L0591C08 Sales and/or Use Tax (State,Local,MTA) 1984-09-14

Were stationary billboard rentals and custom-painted logos or lettering on vehicles and equipment taxable in Texas?

Short answer: Stationary billboard rentals were not taxable because they were real-property rentals. Painting logos or lettering on trucks, cars, and equipment was taxable as printing or imprinting under Section 151.005(4).

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 an official Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. Letters on STAR can be the basis of a detrimental reliance claim only for the taxpayer to whom the letter was directly issued (see 34 Tex. Admin. Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional about your specific situation.
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 treated stationary billboard rentals as rentals of real property, so they were not subject to state sales tax.

Painting logos and lettering on trucks, cars, and equipment was taxable as printing or imprinting under Section 151.005(4).

What this means for you

Billboard operators

The letter's nontaxable result was limited to stationary billboard rental as real property.

Sign painters and vehicle-lettering businesses

Custom painting on vehicles and equipment was a taxable printing or imprinting service.

Accountants and tax professionals

Separate real-property rental receipts from lettering and production services, and verify the current cited provision.

Common questions

Q: Was stationary billboard rental taxable?
A: No.

Q: Was painting a logo on a truck taxable?
A: Yes.

Q: How did the letter classify vehicle lettering?
A: As printing or imprinting.

Citations and references

  • Tex. Tax Code § 151.005(4) (as cited in the letter)

Source

Original ruling text

September 14, 1984

Dear **:

Thank you for your letter of August 24, 1984, regarding the taxation of
stationary billboard rentals and custom-lettered trucks, cars and equipment.

The rentals of stationary billboards are considered to be the rental of
real property and are therefore not subject to the state sales tax.

The painting of logos and lettering on trucks, cars and equipment is
taxable as printing or imprinting. Tex. Tax Code SEC. 151.005(4).

I have enclosed a copy of the sales tax refund procedure.

This opinion is based upon the facts you presented. If there are
additional or different facts, this opinion may change.

Please feel free to contact me if you have additional questions. You may
write me, call toll free 1-800-252-5555 from anywhere in Texas or phone
512/475-1931.

Sincerely,

Miss Jeannon Kralj
Tax Policy Section
Tax Administration Division

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