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Ezel / Tax Rulings / TX
TX 8510L0667D12 Sales and/or Use Tax (State,Local,MTA) 1985-10-07

Were aircraft carpet replacement, carpet cleaning, freight-box fabrication, and cargo-net fabrication taxable in Texas?

Short answer: Qualified-aircraft carpet replacement was exempt, but carpet cleaning, freight-box construction, and cargo-net fabrication were taxable.

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 applying then-current carrier and cleaning rules to carpet replacement and cleaning in an airplane, plus freight-box and cargo-net fabrication. STAR's caption mentions motor vehicles and boats, but the reproduced body discusses only aircraft and airline-related work, so this page follows the body. Current aircraft, carrier, carpet, cleaning, fabrication, customer-furnished-material, and sales-tax rules may differ, and STAR documents may no longer represent current policy even when not marked superseded.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 business did not have to collect tax when replacing carpet in an airplane that qualified for exemption under Rule 3.297(a)(1). Cleaning carpet in an airplane was taxable under Rule 3.310(b).

Building freight boxes and making cargo nets were taxable even when the airline supplied all materials.

Common questions

Was qualifying-aircraft carpet replacement taxable? No.

Was aircraft carpet cleaning taxable? Yes.

Were freight boxes and cargo nets taxable when the airline supplied materials? Yes.

Did the reproduced body address motor vehicles or boats? No.

Citations and references

  • Texas Comptroller Rule 3.297(a)(1) — qualifying aircraft exemption.
  • Texas Comptroller Rule 3.310(b) — carpet cleaning.

Source

Original ruling text

October 7, 1985

Dear ***:

Thank you for your letter of September 25, 1985 concerning your
company's sales tax responsibility.

You are not required to charge sales tax when you replace carpet in an
airplane which qualifies for exemption under section (a)(1) of the
enclosed Rule 3.297. You are required to charge sales tax when you
clean carpet in an airplane. See section (b) of Rule 3.310.

You are also required to collect sales tax when you build boxes for
freight and make cargo nets, even when the airline furnishes all the
materials.

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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