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Ezel / Tax Rulings / TX
TX 8511L0679C05 Sales and/or Use Tax (State,Local,MTA) 1985-11-08

How were a public Sesquicentennial committee's purchases and sales of medallions and other merchandise taxed in Texas?

Short answer: Necessary committee purchases were exempt, designated Lone Star Medallions were exempt, but other merchandise sales were taxable and required a permit.

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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 based on a committee appointed by a county commissioners court for 1986 Sesquicentennial activities. It distinguishes necessary public-agency purchases, goods bought for resale, designated Lone Star Medallions, and other commemorative or promotional products. The reproduced body does not state the March 31, 1987 endpoint named in STAR's caption. It expressly says different facts could change the opinion. Current public-agency, event, permit, resale, commemorative-product, and sales-tax rules may differ, and STAR documents may no longer represent current policy even when not marked superseded.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

Because the committee was appointed by the county commissioners court, the Comptroller treated it as a public agency exempt on items necessary to carry out its functions.

If the committee sold tangible personal property during the celebration, it needed a sales-tax permit and could give suppliers resale certificates for goods bought for resale. Lone Star Medallions designated by the Texas 1986 Sesquicentennial Commission were exempt. Other tangible personal property—including licensed, official, commemorative, or promotional products—was taxable when sold.

Common questions

Were necessary committee purchases exempt? Yes.

Were designated Lone Star Medallions taxable? No.

Were other commemorative products taxable? Yes.

Did merchandise sales require a permit? Yes.

Citations and references

The reproduced letter cites no numbered statute or rule.

Source

Original ruling text

November 8, 1985

Dear ***:

I have received your exemption certificate for the COMMITTEE.

On the exemption certificate you are claiming an exemption because:
"Items purchased will be sold in 1986 during the planned activities
which have been approved by the Texas 1986 Sesquicentennial Commission
for the City of ***, Texas on May 2, 1984."

If the Committee will be selling tangible personal property during the
Sesquicentennial celebration, the Committee will need a sales tax permit.
The Committee will then provide a resale certificate to any suppliers in
lieu of tax on goods purchased for resale.

Lone Star Medallions designated by the Texas 1986 Sesquicentennial
Commission are exempt from sales tax. The sale of other tangible
personal property, even licensed, official, commemorative or promotional
products is subject to tax.

I understand the Committee was appointed by the Commissioner's Court.
The Committee is a public agency and will be exempt from tax on items
necessary to carry out the function of the Committee.

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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