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Ezel / Tax Rulings / TX
TX 8708L0830B06 Sales and/or Use Tax (State,Local,MTA) 1987-08-19

Did radioactive gold seeds permanently implanted in the body to treat malignant tumors qualify for Texas sales-tax exemption?

Short answer: Yes. The Comptroller said radioactive gold seeds qualified for exemption when they were permanently implanted in the human body.

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 is a taxpayer-specific August 1987 Texas Comptroller letter about radioactive gold seeds used to treat malignant tumors. It says the opinion may change if the facts differ. The body gives no statutory basis and ties exemption to permanent implantation; verify current medical-item law. STAR documents may no longer represent current policy even when not marked superseded.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

Radioactive gold seeds used in treating malignant tumors qualified for exemption when they were permanently implanted in the human body.

What this means for you

The historical answer is narrow. It addresses permanent implantation and does not explain the treatment of temporary use, other radioactive materials, or nonimplant procedures.

Common questions

Did the gold seeds qualify for exemption? Yes.

What fact did the letter specify? The seeds were permanently implanted in the human body.

Did the letter cite a statute or rule? No.

Citations and references

  • No statute or rule number is cited in the ruling text.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

August 19, 1987

Dear ***:

Thank you for your letter of August 10, 1987, concerning the taxability
of radioactive gold seeds used in the treatment of malignant tumors.

The radioactive gold seeds which are permanently implanted in the human
body qualify for exemption.

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 Policy Division.

Sincerely,
Eddie C. Washington
Tax Policy Division

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