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TX 9303985L Motor Vehicle Tax 1993-03-05

When did Texas exempt an ambulance or fire truck purchased by a volunteer emergency-services organization?

Short answer: The exemption applied when a volunteer fire department bought the vehicle, or when an eligible § 501(c)(3) volunteer EMS provider with at least 75% unpaid staff bought it. The vehicle had to be used exclusively for firefighting or emergency medical services.

Apply this to your situation

This page answers the general question as of 1993. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1993
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 Tax Administration letter issued on one organization's 1993 ambulance purchase. It predates modern Private Letter Ruling reliance terms and cannot bind the Comptroller for unrelated taxpayers. Section 152.087, federal nonprofit references, the 75% volunteer threshold, exclusive-use requirements, affidavit forms, and qualifying emergency-service entities may have changed. 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 Administration Division explained the historical vehicle exemption for volunteer emergency services.

Texas Tax Code § 152.087 exempted the purchase, rental, or use of a fire truck, ambulance, or other vehicle used exclusively for firefighting or emergency medical services when acquired by a volunteer fire department.

It also covered a nonprofit volunteer EMS provider exempt under Internal Revenue Code §§ 501(a) and 501(c)(3), provided at least 75% of its staff were unpaid volunteers.

What this means for you

Volunteer fire departments and nonprofit EMS providers

Both the buyer's status and the vehicle's exclusive emergency use mattered.

Emergency vehicle dealers

The letter directed qualifying organizations to claim the exemption on the historical title-tax affidavit.

Common questions

Q: Did a volunteer fire department qualify?

A: Yes, for the exclusively used emergency vehicles described.

Q: What volunteer threshold applied to the nonprofit EMS provider?

A: At least 75% unpaid staff.

Citations and references

  • Texas Tax Code § 152.087 — quoted for the emergency-vehicle exemption.
  • Internal Revenue Code §§ 501(a) and 501(c)(3) — cited for eligible nonprofit EMS status.

Source

Original ruling text

March 5,1993





Dear **:

I have received your letter requesting an exemption from motor vehicle sales
tax on an ambulance purchased by your organization.

Section 152.087 of the Motor Vehicle Sales and Use Tax Statute allows for an
exemption from motor vehicle tax on "the purchase, rental, or use of a fire
truck, ambulance, or other motor vehicle used exclusively for fire-fighting
purposes or for emergency medical services when purchased by:

(1) a volunteer fire department; or

(2) a nonprofit volunteer emergency medical service provider that receives a
federal income tax exemption under Section 501(a), Internal Revenue Code of
1986, as a organization described by Section 501 (c)(3), Internal Revenue Code
of 1986." The staff of the volunteer emergency medical service organization
must consist of at least 75% unpaid volunteers.

If your organization meets the above qualifications, it may claim the exemption
on item 21 of the Motor Vehicle Tax Affidavit portion of the Application for
Texas Certificate of Title.

This opinion is based on the facts presented. If there are additional or
different facts, the opinion could change.

If you have any questions, please don't hesitate to write the Tax
Administration Division or call one of our tax specialist toll free at
1-800-252-5555.

Sincerely,

Joan Hale
Tax Administration Division

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