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Ezel / Tax Rulings / TX
TX 8802L0890G13 Sales and/or Use Tax (State,Local,MTA) 1988-02-04

Were a company's ultrasonic radiography, magnetic-particle, and dye-penetrant testing services taxable in Texas?

Short answer: No. Texas treated the described nondestructive testing services—ultrasonic radiography, magnetic-particle testing, and dye-penetrant testing—as nontaxable testing services.

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. It says the opinion may change if the facts differ and cites no statute or rule. STAR's caption names semiconductors, chips, metal, oil equipment, and welds, but the operative body identifies only three nondestructive-testing methods; this page does not extend the holding to other services or products. Testing-service 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 STAR documents may no longer represent current policy even when not marked superseded.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

The company provided nondestructive testing using ultrasonic radiography, magnetic-particle testing, and dye-penetrant testing. The Comptroller said those were nontaxable testing services.

What this means for you

The holding is limited to the three methods described in the letter. The operative text does not identify the particular objects tested or classify testing of semiconductors, chips, metal, oil equipment, or welds separately despite STAR's broader caption.

Common questions

Was ultrasonic radiography taxable? No, as part of the described nondestructive-testing services.

Were magnetic-particle and dye-penetrant testing taxable? No.

Did the letter cite a governing statute or rule? No.

Citations and references

The letter cites no numbered statute or rule.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 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.

According to your letter, your company provides nondestructive testing
services which include ultrasonic radiography, magnetic particle and dye
penetrant. These are nontaxable testing services.

This opinion is based on the facts presented. If there are additional or
different facts, the opinion may change.

Sincerely,
Adina Whittemore
Tax Policy Division

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