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Ezel / Tax Rulings / TX
TX 8803001L Sales and/or Use Tax (State,Local,MTA) 1988-03-23

Was the proposed Texas electricity sales-tax exemption certificate acceptable, and what was missing when a nonregistered engineer certified the study?

Short answer: The certificate was otherwise acceptable, but it needed the owner's certification when the study was certified by an engineer who was not registered. Identifying the engineering college was suggested.

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 an official 1988 Texas Comptroller of Public Accounts letter reviewing one proposed exemption-certificate form, published on STAR. It does not reproduce the certificate or identify a rule number, and current electricity exemptions and certification requirements must be verified independently. The operative body does not state the broader before-and-after rule history named in STAR's caption, so this summary does not repeat it as a holding. Another taxpayer should not treat this form-specific letter as binding. 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 reviewed a proposed sales-tax exemption certificate for use with customers. The certificate was acceptable except for one missing item.

When the underlying study was certified by an engineer who was not a registered engineer, the certificate needed the owner's certification. The Comptroller also suggested that the engineer identify the engineering college.

What this means for you

This was an approval of a specific proposed form subject to a required correction. The official STAR text does not include the certificate itself, so the exact wording cannot be reconstructed from the letter.

Common questions

Was the proposed certificate accepted as submitted? Not quite. It needed owner certification in the stated nonregistered-engineer situation.

Was identifying the engineering college mandatory? The letter suggested it but described the owner's certification as the needed addition.

Did the body explain STAR's captioned rule-revision history? No.

Citations and references

The letter did not cite a rule or statute by number.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS

STATE OF TEXAS

AUSTIN, 78774

BOB BULLOCK

Comptroller March 23, 1988

Dear **:

The sales tax exemption certificate that you propose to provide to your

customers has been reviewed.

The certificate needs the owner's certification that is required when

the study is certified by an engineer who is not a registered engineer.

It is suggested that the engineer identify the engineering college. The

certificate is acceptable otherwise.

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,

(Mrs.) Jo Ann Dieck

Tax Policy Division

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