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Ezel / Tax Rulings / TX
TX 8608L0750B04 Sales and/or Use Tax (State,Local,MTA) 1986-08-20

Was the full charge for retreading tires taxable, including a separately invoiced charge to repair the tire casing?

Short answer: Yes. The entire retreading charge was taxable, including casing repair because it was part of the retread process. Separating or changing the invoice presentation did not change taxability.

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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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

The Comptroller said the total charge for retreading tires was taxable. A charge to repair the casing was also taxable because casing repair formed part of the retread process.

The way the business presented those amounts on its invoice did not change their taxability.

Common questions

Was the full tire-retreading charge taxable? Yes.

Could casing repair be treated as a separate nontaxable charge? No. It was part of the retread process and taxable.

Did separately stating the charges change the result? No. The method of invoicing did not affect taxability.

Source

Original ruling text

August 20, 1986

Dear ***

Thank you for your letter of August 5, 1986, concerning the invoicing of
tire retread charges.

The total charge for retreading tires is taxable. The charge to repair
the casing is taxable since it is a part of the retread process. The
method of invoicing will not affect the taxability.

This opinion is based upon the facts you presented. If there are
additional or different facts, this opinion may change.

Please feel free to contact us if you have additional questions. You may
write us, call toll free 1-800-252-5555 from anywhere in Texas.

Sincerely,

Tax Policy Section
Tax Administration Division

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