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Ezel / Tax Rulings / TX
TX 8607L0749E04 Sales and/or Use Tax (State,Local,MTA) 1986-07-18

Was a hospital's charge for providing copies of medical records to third parties subject to Texas sales tax?

Short answer: No. The Comptroller treated the copies as part of the hospital's professional service and said providing them to third parties was not subject to tax.

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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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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

A hospital was considering providing copies of medical records to third parties.

The Comptroller concluded that providing those copies was part of the professional service furnished by the hospital and was not subject to tax.

Common questions

Were the medical-record copies taxable? No.

Why not? The letter treated them as part of the hospital's professional service.

Did the recipient have to be the patient? The letter specifically described copies provided to third parties.

Source

Original ruling text

July 18, 1986

Dear ***:

Thank you for your letter of June 27, 1986, concerning tax on copies of
medical records.

I understand the hospital is considering providing copies of medical
records to third parties. The provision of copies of medical records
by the hospital is a part of the professional service provided by the
hospital and is not subject to tax.

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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