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Ezel / Tax Rulings / TX
TX 9001L0978E08 Motor Vehicle Tax 1990-01-26

Could a vehicle lessor buy repair and replacement parts for rental tractors and trailers tax-free?

Short answer: Yes. The 1990 letter allowed repair and replacement parts installed on rental or leased tractors and trailers to be purchased tax-free from Texas suppliers with a properly completed resale certificate validated by a Texas permit number or home-state retailer registration number.

Apply this to your situation

This page answers the general question as of 1990. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1990
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 1990 Texas Tax Correspondence letter issued on repair and replacement parts for rented or leased tractors and semitrailers. It predates modern Private Letter Ruling reliance terms and cannot bind the Comptroller for unrelated taxpayers. Rule 3.87, resale eligibility, certificates, permit validation, out-of-state registration numbers, parts, accessories, and vehicle lessor obligations may have changed. The enclosed certificate is not reproduced in STAR. 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 Texas Tax Correspondence Division allowed repair and replacement parts installed on rental or leased tractors and trailers to be purchased tax-free from Texas suppliers.

The buyer had to give a properly completed Texas resale certificate validated with its Texas sales or use tax permit number or its home-state retailer registration number.

What this means for you

Verify current Rule 3.87, certificate language, permit requirements, and later tax responsibilities before purchasing parts tax-free.

Common questions

Q: What documentation did the letter require?

A: A properly completed resale certificate with the applicable permit or registration number.

Citations and references

  • 34 Tex. Admin. Code Rule 3.87(b)(1) — cited for accessories added to motor vehicles.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, TEXAS 78774

January 26, 1990

Dear ***:

Thank you for your recent letter regarding the taxability of the
repairs and/or replacement parts for motor vehicles that are
leased or rented. You specifically mentioned semi-trailers.

You may purchase repair and replacement parts to be installed on
your rental or lease tractors and trailers (motor vehicles) tax
free from Texas suppliers by issuing a properly completed Texas
resale certificate. The resale certificate must be validated
with your Texas sales or use tax permit number of your retailer
registration number from your state. Please refer to section
(b)(1) of our Rule 3.87 on Accessories Added to Motor Vehicles.
I am enclosing a resale certificate for your use. The certificate
may be reproduced.

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 additional information, you may
call me toll free at 1-800-252-5555, extension 5-0330. The
regular number is 512/463-4600, or write me at Tax Correspondence,
Comptroller of Public Accounts.

Sincerely,
Bettie U. Peterson
Tax Correspondence Division

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