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Ezel / Tax Rulings / TX
TX 8611L0775A01 Sales and/or Use Tax (State,Local,MTA) 1986-11-10

Were copies of court, bankruptcy, probate, real-property, and other governmental records sold by a research service subject to Texas sales tax?

Short answer: Yes. The Comptroller said sales of copies of documents, publications, or general information obtained from governmental entities were taxable transactions.

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 treats the sale of copies or general information obtained from governmental entities as taxable, despite the taxpayer's report of earlier informal advice. It does not separately allocate research and copying charges. Government-record, research, information-service, reproduction, digital-delivery, court-fee, public-information, 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 STAR documents may no longer represent current policy even when not marked superseded.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 sales of copies of documents, publications, or general information obtained from a governmental entity were taxable.

The business located courthouse files, researched them, reproduced requested information, and forwarded it to clients. The answer required tax on those sales and did not adopt the taxpayer's understanding that only additional copy sets were taxable.

What this means for you

The ruling treated the customer transaction as a taxable sale of government-derived documents or information. It did not separately distinguish the research labor from the delivered copies.

Common questions

Were government-record copies taxable? Yes.

Did the ruling tax only second or additional sets? No.

Did it separately classify the research charge? No.

Citations and references

  • The letter cited no numbered statute or Comptroller rule.

Source

Original ruling text

November 10, 1986

Dear ***:

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

Our customers call us requesting information on different types of
documents (bankruptcies, district court, real property, probate, etc.)
filed at various courthouses. We locate these files, research the
documents, reproduce the information needed and forward it to our clients.
We were informed by the State Comptroller's Office that the work we do
is non-taxable, but if our customer requires more than one set of the
instruments, the additional sets are taxable.

Response:
The sale of copies of documents, publications or general information
obtained from a governmental entity is a taxable transaction. Therefore
you must collect tax on these.

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

Sincerely,

Tax Policy Section
Tax Administration Division

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