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Ezel / Tax Rulings / TX
TX 8611L0774A03 Sales and/or Use Tax (State,Local,MTA) 1986-11-21

Were separately stated storage and transportation charges taxable when a restoration company moved, cleaned, stored, and returned damaged household goods?

Short answer: Yes. Texas treated both the separately stated storage fee and the pickup, delivery, and handling transportation charge as taxable under the described restoration arrangement.

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 1986 Texas Comptroller letter decides only separately stated storage and transportation charges for household goods moved, cleaned, stored, and returned during restoration. The broader STAR caption mentions water extraction, drying, building components, and residential versus nonresidential realty that the body does not decide. Restoration, cleaning, storage, transportation, handling, real-property, and local-tax rules may have changed. STAR documents may no longer represent current policy even when not marked superseded. Identities 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

The Texas Comptroller said the restoration company's separately stated storage fee was taxable. The company moved damaged household goods from a home or office, cleaned them, and stored them until the customer was ready for redelivery.

The separately stated pickup, delivery, and handling transportation charge was also taxable.

The operative body did not decide water extraction, drying of building components, or residential-versus-nonresidential real-property treatment listed in STAR's broader caption.

What this means for you

Separately listing storage and transportation did not make those charges nontaxable in the described integrated restoration arrangement.

Common questions

Was the storage fee taxable? Yes.

Was the transportation charge taxable? Yes.

Did the letter decide water extraction or drying charges? No.

Citations and references

  • The letter cited no numbered statute or Comptroller rule.

Source

Original ruling text

November 21, 1986

Dear ***:

Thank you for your recent letter which is restated with response below.

Our company is in the business of providing restoration
services (i.e. carpet and furniture cleaning, duct work
cleaning and deodorization, furniture and upholstery repair,
and moving, cleaning and storing household goods damaged from
fire or water.)

In conjunction with the services we provide, we charge our
customer for storage, as a separate line item, for their
household goods. After we move their furniture from their
home or office to our building, we clean it and store it in
our crate until all items have been cleaned and the customer
is ready for delivery. We also charge our customer for
pick-up and delivery and handling as a separate line item on
the invoice.

Our question is this:

1) Is the fee for storage, in light of the above situation,
taxable to our customer?

Response: Yes.

2) Is the transportation charge, in light of the above
situation, subject to sales tax?

Response: Yes.

If you have any questions or need more information, please call me at
1-800-252-5555 toll free from anywhere in Texas. The regular number is
512/463-4600. You may write me at the Tax Administration Division.

Sincerely,

Tax Policy Section
Tax Administration Division

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