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Ezel / Tax Rulings / TX
TX 9202L1155D07 Sales and/or Use Tax (State,Local,MTA) 1992-02-06

Were public admission charges to automobile shows run by Section 501(c)(6) new-car trade associations taxable in Texas?

Short answer: No. The Comptroller said the trade associations' public auto-show admissions were exempt under Rule 3.298(g)(1)(A).

Apply this to your situation

This page answers the general question as of 1992. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1992
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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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

Federally tax-exempt new-car trade associations organized automobile shows and charged the general public admission.

The Comptroller said the admissions were exempt under Rule 3.298(g)(1)(A) because the associations qualified under Internal Revenue Code § 501(c)(6).

What this means for you

Trade associations

The result depended on the organizer's Section 501(c)(6) status and the specific amusement-services exemption cited in the letter.

Event operators and tax professionals

Do not assume all auto-show admissions are exempt. Confirm the organizer's status and current Rule 3.298 requirements.

Common questions

Were the public admission charges taxable? No.

What was the organizer's federal status? Section 501(c)(6).

What Texas rule provided the exemption? Rule 3.298(g)(1)(A).

Citations and references

  • Internal Revenue Code § 501(c)(6) (business leagues and trade associations)
  • 34 Tex. Admin. Code Rule 3.298(g)(1)(A) (exempt amusement admissions)

Source

Original ruling text

February 6, 1992

Dear **:

Thank you for your letter of January 29, 1992, concerning the
taxability of admissions charged to the general public to attend
automobile shows that are put on by new car trade associations.

The trade associations are exempt from federal income tax under
Section 501(c)(6) of the Internal Revenue Code. The admissions
charged by the trade associations to the public to attend the
trade shows are exempt under section (g) (1) (A) of the enclosed
Rule 3.298 - Amusement Services.

This opinion is based on the facts that you presented. If there
are additional or different facts, this opinion may change.

You may call 512/463-4600 if you have any questions or need more
information. You may write to Tax Administration Division,
Comptroller of Public Accounts.

Sincerely,

Eddie C. Washington
Tax Administration Division

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