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Ezel / Tax Rulings / TX
TX 8802L0867B11 Sales and/or Use Tax (State,Local,MTA) 1988-02-04

Were two-way and C.B. radios sold to farmers or ranchers exempt as agricultural equipment, and were installation charges taxable?

Short answer: No agricultural exemption applied. Two-way and C.B. radios remained taxable even when installed in a tractor or combine, and installation charges were also taxable beginning October 1, 1987.

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 February 1988 Texas Comptroller letter applying a sales-tax change effective October 1, 1987. It says the opinion may change if the facts differ and cites no statute or rule. STAR's caption mentions shared repeater services, but the operative body decides only radio sales and installation; this page does not classify repeater service. Agricultural and installation rules may have changed; verify current law. STAR documents may no longer represent current policy even when not marked superseded. Taxpayer-identifying details 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

Two-way radios and citizen-band radios sold to farmers and ranchers were taxable, even when installed in a tractor or combine. The Comptroller said they did not qualify as agricultural machinery or equipment.

Installation charges also became taxable on October 1, 1987, even when separately stated.

What this means for you

Under this historical letter, farm or ranch use did not by itself exempt communication equipment. The letter did not address shared repeater services despite STAR's caption.

Common questions

Were two-way radios exempt for farmers? No.

Did installation in a tractor or combine change the answer? No.

Were separately stated installation charges taxable? Yes, beginning October 1, 1987.

Citations and references

The letter cites no numbered statute or rule.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, TEXAS 78774

February 4, 1988

Dear *:

On behalf of Mr. Bullock, I hope you'll accept my apology for the delay
in answering your question involving changes in the sales tax law. 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 businesses. In many instances, an answer to a
question just wasn't available when the question arrived.

Two-way radios, as well as citizen band (C.B.) radios, are taxable when
sold to farmers and ranchers. The radios are not exempt as agricultural
machinery or equipment, even if installed in a tractor or combine.

As of October 1, 1987, the charge for installing the radios is also
taxable, even if the installation charge is separately stated.

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 our toll-
free number 1-800-531-5441. 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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