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Ezel / Tax Rulings / TX
TX 8509L0663C04 Sales and/or Use Tax (State,Local,MTA) 1985-09-13

Was a voice-message retrieval service that signaled customers' pagers taxable in Texas?

Short answer: Yes. The Comptroller classified it as taxable telecommunications service, including telephone paging, rather than excluded computer time sharing.

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This page answers the general question as of 1985. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1985
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 1985 Texas Comptroller taxpayer-response letter classifying a described voice-message retrieval service with automatic pager alerts as taxable telecommunications service. Its explanation limits the quoted storage-and-retrieval exclusion to computer time sharing as then defined. It expressly says different facts could change the opinion. Current voicemail, paging, computer-service, telecommunications, and sales-tax rules may differ, and STAR documents may no longer represent current policy even when not marked superseded. Letters on STAR can support detrimental reliance only for the taxpayer to whom the letter was directly issued under 34 Tex. Admin. Code Rules 3.1 and 3.10. Taxpayer-identifying 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

The client's service recorded a caller's message, automatically signaled the customer's pager, and let the customer retrieve the message through a telephone-company line not owned by the provider.

The Comptroller treated the service as taxable telecommunications service, which included mobile telephone and telephone paging services. The exclusion for storing information for later retrieval was limited to computer time sharing, described as remote-terminal access to a computer.

Common questions

Was the voice-retrieval service taxable? Yes.

Why? It was classified as telecommunications service that included telephone paging.

Did the storage-and-retrieval exclusion apply? No; the letter limited it to computer time sharing.

Citations and references

The reproduced letter cites no numbered statute or rule.

Source

Original ruling text

September 13, 1985

Dear ***:

Thank you for your letter of September 6, 1985, concerning the
taxability of a voice retrievable service.

Your client provides a voice retrievable service for its customers. A
person attempting to call your client's customer leaves a message that
your client's customer can later retrieve. When a message is placed on
the customer's machine a signal is automatically sent to the customer's
pager indicating that the customer can call and retrieve the message.
The call to retrieve the message is placed on a telephone company line
not owned by your client.

The voice retrievable service is taxable as telecommunications service
which includes mobile telephone and telephone paging services.

The exclusion from telecommunications services of "the storage of data or
information for subsequent retrieval or the processing, or reception and
processing, of data or information" is limited to computer time sharing.
Time sharing means providing a customer with access to a computer
through remote terminals.

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

If you have any questions or need more information, please call us at
1-800-252-5555 toll free from anywhere in Texas. You may write us at the
Tax Administration Division.

Sincerely,

Tax Policy Section
Tax Administration Division

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