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Ezel / Tax Rulings / TX
TX 8709L0829F01 Sales and/or Use Tax (State,Local,MTA) 1987-09-14

Was a separate customer charge for manufacturer-supplied shop drawings used as installation instructions taxable in Texas?

Short answer: Yes. The shop drawings were a taxable sale of tangible personal property even though they were separately charged installation instructions.

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 September 1987 Texas Comptroller letter about manufacturer-supplied shop drawings sold as installation instructions. It says the opinion may change if the facts differ. Its tangible-property classification is historical; verify current treatment of drawings, digital delivery, and bundled design services. STAR documents may no longer represent current policy even when not marked superseded.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 seller provided shop drawings as installation instructions for materials it sold. It obtained the drawings from the materials' manufacturer and charged the customer separately for them.

The Comptroller treated the shop-drawing charge as a taxable sale of tangible personal property.

What this means for you

The historical letter did not treat the drawings as a nontaxable instruction service merely because they accompanied other materials or appeared as a separate line item. The drawings themselves were the taxable property sold.

Common questions

What were the shop drawings used for? Installation instructions for materials the business sold.

Were they separately charged? Yes.

Was that charge taxable? Yes, as tangible personal property.

Citations and references

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

Source

Original ruling text

September 14, 1987

Dear ***:

Thank you for your letter concerning the taxability of shop drawings.

According to the information you provided, shop drawings are installation
instructions for materials that you sell. A separate charge to the
customer
is made for the drawings, which are obtained from the manufacturer of the
materials.

The charge for the shop drawings is a taxable sale of tangible personal
property.

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,

Julie Pesl
Tax Policy Division

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