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Ezel / Tax Rulings / TX
TX 8604L0719A14 Sales and/or Use Tax (State,Local,MTA) 1986-04-07

Could a telephone company accept one blanket exemption certificate for a customer's multiple locations?

Short answer: Yes, if every location and number was identified. The certificate also had to describe the services plainly and list the purchaser's phone number.

Apply this to your situation

This page answers the general question as of 1986. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1986
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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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 Comptroller said one blanket exemption certificate could cover a customer's multiple business locations, including chains, hospitals with branch offices, and nonprofit day-care centers, as long as every location and number was identified.

The “description of items to be purchased” section had to describe the services provided in ordinary, nontechnical language. The “phone” field was for the purchaser's telephone number, not the customer's account number.

Common questions

Can one certificate cover several locations? Yes, if all locations and numbers are identified.

What belongs in the description field? A plain-language description of the services provided.

What belongs in the phone field? The purchaser's phone number.

Citations and references

The reproduced letter does not cite a statute or rule.

Source

Original ruling text

April 7, 1986

Dear ***:

Thank you for your letter of March 26, 1986, concerning exemption
certificates.

  1. In cases of multi-location business such as chains, hospitals with
    several branch offices, or nonprofit Day care centers with several
    locations, etc., would a blanket form suffice to meet your requirements?

Yes, a blanket exemption certificate will be sufficient as long as all
locations and numbers are identified.

  1. Under "description of items to be purchased", what statement
    should be used for multi-location or multi-account business?

This section should clearly state the services provided in layman's terms.

  1. We are under the impression that the customers account number
    goes in the "phone" space on your form, therefore, in the attached
    example the number *** is wrong. The customer should have
    entered     *****. Do we have a understanding of what this entry
    is used for?

The "phone" space on the form is for the purchaser's phone number.

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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