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Ezel / Tax Rulings / TX
TX 8710L0839A09 Sales and/or Use Tax (State,Local,MTA) 1987-10-16

Were the recipient's delivery, courier, or messenger services taxable under the 1987 Texas sales-tax change?

Short answer: No. The described services were not taxable; only courier services requiring a license under the cited private-security law were taxable.

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 October 1987 Texas Comptroller letter whose body does not describe the recipient's services in detail. It says the opinion may change if the facts differ. Its distinction based on the former cited licensing law is historical; verify current service definitions, licensing, and taxability. STAR documents may no longer represent current policy even when not marked superseded.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 Comptroller said the recipient's services were not taxable. The letter did not describe those services in detail.

It stated that only courier services required to be licensed under the Private Investigators and Private Securities Act, Texas Civil Statutes article 4413(29bb), were taxable.

What this means for you

The historical distinction turned on whether the courier service fell within the cited licensing requirement. Because the letter omits the recipient's detailed facts, it should not be read as exempting every delivery or messenger service.

Common questions

Were the recipient's services taxable? No.

Which courier services did the letter identify as taxable? Those required to be licensed under the cited Private Investigators and Private Securities Act.

Does the letter explain exactly what the recipient did? No.

Citations and references

  • Texas Civil Statutes article 4413(29bb), Private Investigators and Private Securities Act

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, TX 78774

October 16, 1987

Dear ****:

Thank you for your letter of August 31, 1987, concerning your sales tax
responsibilities under the new sales tax law.

The services you perform are not taxable. Only courier services required
to be licensed under the Private Investigators and Private Securities
Act,
Texas Civil Statutes, Article 4413 (29bb) are taxable.

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 phone 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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