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TX 8807L0889C13 Sales and/or Use Tax (State,Local,MTA) 1988-07-21

Are storage charges taxable in Texas — for fur garments, motor vehicles, and other items?

Short answer: Storing fur garments and storing motor vehicles are specifically taxable services in Texas. But a charge to store other kinds of items — when it is not connected with the sale, lease, or rental of the item or with a taxable service — is not taxable.

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 Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. Letters on STAR can be the basis of a detrimental reliance claim only for the taxpayer to whom the letter was directly issued (see 34 Tex. Admin. Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional about your specific situation.
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

Someone asked the Comptroller how Texas sales tax applies to storage charges. The answer draws a clear line:

  • Storing motor vehicles and storing fur garments are services that are specifically taxable.
  • Storing other items is not taxable — as long as the storage charge is for storage only and is not connected with the sale, lease, or rental of the item stored or with the performance of a taxable service.

In short, Texas singles out fur storage (and vehicle storage) as a taxable service, while general storage of other goods, standing alone, is not taxed.

What this means for you

Furriers and fur-storage providers

If you store fur garments, that storage charge is taxable — collect sales tax on it. This is a specifically enumerated taxable service, so don't treat it like ordinary warehousing.

Other storage businesses

Storing other kinds of goods is generally not taxable when the charge is purely for storage. Watch the connection test, though: if the storage is tied to a sale, lease, or rental of the item, or to a taxable service, the charge can become taxable.

Common questions

Q: Is fur storage taxable in Texas?
A: Yes. The Comptroller states that storage of fur garments is a specifically taxable service (as is storage of motor vehicles).

Q: Is storing other items taxable?
A: Not by itself. A charge for storage only of other items is not taxable when it is not connected with the sale, lease, or rental of the item or with a taxable service.

Q: What makes otherwise-nontaxable storage become taxable?
A: A connection to the sale, lease, or rental of the stored item, or to the performance of a taxable service.

Q: Can I rely on this 1988 letter today?
A: Treat it as guidance only. It is based on the facts presented and can change with different facts; on the STAR system it binds the Comptroller only as to the taxpayer it was issued to and may no longer reflect current policy.

Citations and references

Rules and statutes: The letter identifies storage of fur garments and motor vehicles as specifically taxable services and other storage as nontaxable when unconnected to a sale/lease/rental or taxable service, but does not cite a specific Tax Code section or Comptroller rule by number.

Source

Original ruling text

July 21, 1988




Dear *****:

Thank you for your recent letter regarding the taxability of storage charges.

Storage of motor vehicles and storage of fur garments are services which are
specifically taxable.

A charge for storage only of other items that is not connected with the sale,
lease or rental of the item stored or performance of a taxable service is not
taxable.

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 Tax Correspondence, Comptroller of Public Accounts.

Sincerely,

Julie Pesl
Tax Correspondence

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