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Ezel / Tax Rulings / TX
TX 8701L0787G12 Sales and/or Use Tax (State,Local,MTA) 1987-01-13

Were cardiac electrodes sold to Texas hospitals, nursing homes, HMOs, doctors' offices, and clinics subject to sales tax?

Short answer: Yes. The Texas Comptroller said cardiac electrodes were taxable when sold to the listed health-care providers.

Apply this to your situation

This page answers the general question as of 1987. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1987
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 brief 1987 Texas Comptroller letter applies to cardiac electrodes sold to listed health-care providers and cites then-current Rule 3.284. Medical-device, supply, prescription, provider, hospital, clinic, HMO, exemption, and local-tax rules may have changed or differ for other electrodes and purchasers. STAR documents may no longer represent current policy even when not marked superseded.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 cardiac electrodes were taxable when sold to hospitals, nursing homes, HMO groups, doctors' offices, clinics, and similar health-care providers.

The short letter gave no further product-specific reasoning and referred the taxpayer to Rule 3.284 on drugs and medicine.

What this means for you

Institutional or medical use did not make the electrode sale exempt under this ruling. The holding is limited to the named product and purchaser categories.

Common questions

Were cardiac electrodes taxable? Yes.

Did sale to a hospital or clinic make them exempt? No.

What rule did the letter cite? Comptroller Rule 3.284.

Citations and references

  • Comptroller Rule 3.284 — drugs and medicine.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, TX 78774

BOB BULLOCK
Comptroller January 13, 1987

Dear *:

Thank you for your letter of December 12, 1986 concerning the taxability
of
cardiac electrodes sold to HMO groups within Texas.

The cardiac electrodes are taxable when sold to hospitals, nursing homes,
HMO
groups, doctor's offices, clinics, etc. Rule 3.284, Drugs and Medicine,
is
enclosed for your reference.

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 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,
Julie Pesl
Tax Policy Section
Tax Administration Division

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