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Ezel / Tax Rulings / TX
TX 8801L0900C09 Sales and/or Use Tax (State,Local,MTA) 1988-01-25

Was an annual contract to train and advise a company's emergency response teams subject to Texas sales tax?

Short answer: No. The Comptroller said the service was not taxable where the provider trained and advised emergency response teams in firefighting, first aid, and hazardous-material handling and delivered no tangible product.

Apply this to your situation

This page answers the general question as of 1988. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1988
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 January 1988 Texas Comptroller letter based on an annual emergency-response training and advisory contract with no tangible product other than training and advice. It says the opinion may change if the facts differ. The taxability of training, consulting, digital materials, and bundled deliverables may have changed substantially; verify current law and every item provided. STAR documents may no longer represent current policy even when not marked superseded.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 provider had an annual contract to train and advise a company's emergency response teams in firefighting, first aid, and handling hazardous materials. The provider said there was no tangible product other than the training and advice.

The Comptroller's answer was direct: based on those facts, the service was not taxable.

What this means for you

The letter addressed a service-only training arrangement. It did not discuss manuals, equipment, recorded courses, software, or separately sold materials, so it does not decide how those additions would be taxed.

Common questions

Was the yearly training contract taxable? No, under the facts presented.

What subjects did the training cover? Firefighting, first aid, and hazardous-material handling for emergency response teams.

Did the provider deliver any tangible product? The letter says there was no tangible product other than training and advice.

Citations and references

  • No statute or administrative rule is cited in the letter text.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

January 25, 1988

Dear *****:

On behalf of Mr. Bullock, I hope you'll accept my apology for the delay
in answering your question involving the taxability of services you render to
***. This isn't the way we normally do business.

Our people were, and still are, swamped by a deluge of inquiries as they
attempted to interpret provisions of the new law and draft rules which would
not adversely impact business. In many instances, an answer to a question just
wasn't available when the question arrived.

You stated that you have a yearly contract to train and advise the
Emergency Response Teams of *** in fire fighting, first aid and handling
of hazardous materials and there is no tangible product other than training and
advise.

Based on the facts present, your service is not taxable.

This opinion is based on the facts you presented. If there are
additional or different facts, this 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 Telephone Bank Operations.

Sincerely,

Gloria Anglin
Telephone Bank Operations

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