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Ezel / Tax Rulings / TX
TX 8411L0603B14 Sales and/or Use Tax (State,Local,MTA) 1984-11-09

Were charges for trucking uranium ore taxable when the carrier did not sell the uranium?

Short answer: No. Transportation charges for moving uranium were nontaxable when the company provided trucking only; the letter said the result changed if the company also sold the uranium.

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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 said charges to a customer for trucking uranium ore were not taxable when the company provided transportation only.

The letter added an express limitation: the transportation charges would not receive that treatment if the trucking company was also selling the uranium.

What this means for you

Trucking and delivery companies

The nontaxable conclusion depended on providing transportation rather than making a sale of the transported property.

Uranium sellers

The letter did not say transportation charges remained nontaxable when the same business also sold the uranium.

Accountants and tax professionals

Document whether the carrier had any role as seller, because that fact controlled the stated conclusion.

Common questions

Q: Were standalone uranium trucking charges taxable?
A: No.

Q: Did the conclusion apply if the trucking company also sold the uranium?
A: No. The letter expressly excluded that situation from its nontaxable answer.

Citations and references

  • The letter cites no statute or administrative rule.

Source

Original ruling text

November 9, 1984

Dear **:

Thank you for your recent letter regarding the taxability of trucking
uranium ore.

Your transportation charges to your customer for movement of uranium
are not taxable unless you are also selling uranium.

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.

Sincerely,

Al Van Allen
Tax Policy
Tax Administration Division

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