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Ezel / Tax Rulings / TX
TX 8803L0883C04 Sales and/or Use Tax (State,Local,MTA) 1988-03-07

Could a supplier accept the exemption certificate printed on a purchase order for property bought for offshore exploration outside Texas?

Short answer: Yes. The Comptroller found the purchase-order certificate sufficient for the described out-of-Texas offshore exploration use, so the supplier could accept it instead of tax.

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 purchase-order exemption certificate, published on STAR. The certificate itself is not included, and the conclusion depends on property bought for offshore exploration outside Texas; verify current exemption wording, documentation, and use requirements before relying on a similar form. Another taxpayer should not treat this form-specific letter as binding. STAR documents may no longer represent current policy. 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 requester bought tangible personal property for offshore exploration use outside Texas and printed an exemption certificate on its purchase order.

The Comptroller said that certificate was sufficient under the presented facts. The supplier could accept it instead of collecting tax.

What this means for you

The approval was tied to the reviewed form and stated out-of-Texas use. Because STAR does not include the certificate's wording, the letter does not establish that any purchase-order legend is sufficient.

Common questions

Could the supplier accept the printed certificate? Yes.

What was the stated use? Offshore exploration outside Texas.

Does STAR reproduce the approved wording? 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 7, 1988

Dear ***:

Thank you for your letter of February 17, 1988, concerning exemption
certificates.

I have reviewed the exemption certificate printed on your purchase order.

You are buying tangible personal property for use in exploration offshore
outside of Texas. Your exemption certificate printed on your purchase
order
is sufficient. Your supplier may accept this "certificate" in lieu of
tax.

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,
Adina Whittemore
Tax Policy Division

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