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Ezel / Tax Rulings / TX
TX 8803L0875C13 Sales and/or Use Tax (State,Local,MTA) 1988-03-25

When did Texas presume an 800-line call originated in Texas for sales-tax purposes?

Short answer: If station-message records did not establish that the call originated outside Texas, the call was presumed to originate in Texas and Texas sales tax was due.

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 concerning one 800-line recordkeeping capability, published on STAR. Its presumption, telecommunications technology, and call-sourcing treatment are historical; verify current federal and Texas telecom tax rules before applying it today. Letters on STAR can support detrimental reliance only for the taxpayer directly issued the letter and may no longer represent current policy. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional.
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 800-line system could provide station-message detail showing where a call originated.

The Comptroller said that unless the provider determined from those records that a call originated outside Texas, the call would be presumed to have originated in Texas and Texas sales tax would be due.

What this means for you

Under this 1988 letter, documentation controlled the interstate treatment. The absence of proof of out-of-state origin produced a Texas-origin presumption.

Common questions

What evidence could show call origin? A station-message detail record.

What if the provider did not establish an out-of-state origin? Texas origin was presumed and Texas sales tax was due.

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

March 25, 1988

Dear ***:

Thank you for your recent letter to Mr. Holcomb regarding ** 800
lines.

To my understanding, ** has the ability to provide a station message
detail
recording which would show where the call was originated; therefore, if
you
do not determine that the call originated at a point outside Texas, it
will
be assumed that the call originated in Texas and Texas Sales Tax will be
due.

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,
Al Van Allen
Tax Policy Division

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