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Ezel / Tax Rulings / TX
TX 8509L0663E07 Sales and/or Use Tax (State,Local,MTA) 1985-09-17

Was a federally tax-exempt association required to collect Texas sales tax on tickets to its annual football game?

Short answer: No. The Comptroller said the association was exempt from collecting and paying sales tax on the event's ticket sales under Section 151.3101.

Apply this to your situation

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 based on a Section 501(c)(3) association organized primarily to conduct an annual football game. The Comptroller confirmed exemption for the redacted event's ticket sales under then-current Tax Code § 151.3101. STAR's caption names Fair Park, landmark status, and the Cotton Bowl, but those names and facts do not appear in the reproduced body, so this page does not publish them as the operative basis. Current nonprofit, amusement, event, ticket, admission, and sales-tax rules may differ, and STAR documents may no longer represent current policy even when not marked superseded.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. 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 association was organized primarily to conduct an annual football game and was exempt from federal income tax under Internal Revenue Code § 501(c)(3).

The Comptroller confirmed that the association was exempt from collecting and paying sales tax on ticket sales for the event under Texas Tax Code § 151.3101.

Common questions

Were the event's ticket sales taxable? No.

What Texas provision did the letter apply? Section 151.3101.

Did the reproduced body identify Fair Park, landmark status, or the Cotton Bowl? No.

Citations and references

  • Tex. Tax Code § 151.3101(3)-(4) — exemption claimed in the request and confirmed by the Comptroller.
  • Tex. Tax Code § 151.0028 — taxable amusement, entertainment, and recreational services identified in the request.
  • I.R.C. § 501(c)(3) — federal exemption status stated by the association.

Source

Original ruling text

September 17, 1985

Dear ***:

Thank you for your letter of September 9, 1985, which was forwarded to
me for response.

ASSOCIATION ABC is exempt from the collection and payment of sales tax
on ticket sales for the EVENT X under Section 151.3101 of the Texas Tax
Code.

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

September 9, 1985

Dear ***:

On behalf of the ASSOCIATION ABC I have reviewed the new Section
151.0028 of the Texas State Tax Code providing for amusement, en-
tertainment and recreational services as taxable items. ASSOCIATION
ABC was organized primarily to conduct the annual EVENT X football
game and is exempt from federal income tax under Section 501(c)(3)
of the Internal Revenue Code.

We are requesting confirmation from you of our conclusion that we
are exempt from state sales tax on amusement services under Section
151.3101 (3) and (4) of the State Tax Code. Please sign the statement
below verifying our interpretation of the above mentioned code section
and return a copy to me. The duplicate copy is for your files. Thank
you for your cooperation.

Sincerely,

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