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Ezel / Tax Rulings / TX
TX 8410L0599E02 Sales and/or Use Tax (State,Local,MTA) 1984-10-25

What did this Texas letter say about the prior-contract exemption for a fixed-term parking contract?

Short answer: The letter says a fixed-term parking contract entered before October 2, 1843 qualified for the prior-contract exemption through September 30, 1987. Because the printed threshold is 1843, the source does not reliably establish the intended modern cutoff date.

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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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's letter says a fixed-term parking contract entered into before October 2, 1843 qualified for the prior-contract exemption through September 30, 1987.

That 1843 date appears verbatim in the official STAR text. The letter is dated 1984 and discusses an exemption ending in 1987, but the source does not provide a corrected threshold date. This page therefore does not silently change 1843 to 1984 or present the intended cutoff as settled.

What this means for you

Parking operators

The document records that fixed-term parking contracts could qualify for a historical prior-contract exemption, but its printed eligibility date is unusable for determining whether a 1984 contract qualified.

Accountants and tax professionals

Do not infer a corrected date from context alone. A separate official source would be needed to establish the intended threshold.

Common questions

Q: What date does the official text print?
A: October 2, 1843.

Q: When did the letter say the exemption ended?
A: September 30, 1987.

Q: Can this source alone prove that a contract made before October 2, 1984 qualified?
A: No. That would require correcting the source without a verbatim official basis.

Citations and references

  • The letter cites no statute or administrative rule.
  • The October 2, 1843 threshold is reproduced exactly from the official source and is not silently corrected.

Source

Original ruling text

October 25, 1984

Dear **:

Thank you for your recent letter regarding the prior contract exemption
on parking contracts.

If you have entered into a fixed term contract for parking prior to
October 2, 1843, it would qualify for the prior contract exemption until
September 30, 1987.

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, or call toll free 1-800-252-5555 from anywhere in Texas or
phone 512/475-1931.

Sincerely,

Al Van Allen
Tax Policy Section
Tax Administration Division

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