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Ezel / Tax Rulings / TX
TX 9311127L Motor Vehicle Tax 1993-11-13

Were two named Texas Medical Center cooperative associations exempt from motor vehicle sales tax on their purchases?

Short answer: Yes. The approved verbal response accepted that Texas Health and Safety Code §§ 301.013(a) and 301.042(a) exempted the named hospital laundry and heating-and-cooling cooperatives from tax or assessment on their property and purchases, including TECO's vehicle purchase.

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: STAR's source is counsel's 1993 follow-up letter quoting two statutes, marked 'verbal response approved by Tom Soto'; it is not a modern formal Private Letter Ruling. The approval concerns the two specifically named Texas Medical Center cooperatives and does not establish an exemption for cooperatives generally. Sections 301.013 and 301.042, entity status, property and purchase exemptions, and documentation may have changed. Unrelated taxpayers should not treat this record as binding protection. 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

STAR preserves a counsel follow-up letter marked as an approved verbal response concerning two specifically named Texas Medical Center cooperative associations.

Texas Health and Safety Code § 301.013(a) exempted the hospital laundry cooperative from tax or assessment on its property or purchases. Section 301.042(a) provided the same stated exemption for the central heating and cooling service cooperative, known as TECO.

The immediate transaction was TECO's planned motor vehicle purchase, and the record says the dealership might call the Comptroller to confirm TECO's exempt status.

What this means for you

The named cooperatives and hospital systems

The historical approval followed entity-specific statutes, not a general cooperative exemption.

Motor vehicle dealers

Verify current entity status and statutory exemption rather than relying on this 1993 record alone.

Common questions

Q: Were the two named cooperatives treated as exempt?

A: Yes.

Q: Does this exempt every cooperative association?

A: No.

Citations and references

  • Texas Health and Safety Code § 301.013(a) — quoted for the hospital laundry cooperative.
  • Texas Health and Safety Code § 301.042(a) — quoted for the heating and cooling service cooperative.

Source

Original ruling text

[VERBAL RESPONSE APPROVED BY TOM SOTO]

BY TELECOPIER NO. 512-475-0900

November 13, 1993

RE: Texas Medical Center Central Heating and Cooling Services Cooperative
Association
("TECO") and Texas Medical Center Hospital Laundry Cooperative Association (the
"Laundry
Coop")

Mr. Tom Soto
Tax Administration Division
Comptroller of Public Accounts of the State of Texas
First Floor
111 West Sixth Street
Austin, Texas 78711

Dear Tom:

As a follow-up to our telephone conference today, enclosed below are copies of
Sections 301.013(a)[] and 301.042(a)[*] of the Texas Health and Safety Code,
which exempts the Laundry Coop and TECO, respectively, from the Texas Motor
Vehicle Sales Tax.

TECO is in the process of purchasing a motor vehicle from DEALERSHIP and you,
Curt, or Bettie may receive a call from someone at that dealership to confirm
TECO's exempt status.

If you have any questions or need any additional information, please call me at
**. Thank you again for your assistance.

Very truly yours,

cc: **

Vernon's Texas Codes Annotated
Health and Safety Code
Subtitle E. Cooperative Associations
Chapter 301. Cooperative Associations

[*] Texas Medical Center Hospital Laundry Cooperative Association created
under these provisions:
Subchapter A. Hospital Laundry Cooperative Associations
Section 301.013. Tax Exemption
(a) A hospital laundry cooperative association created under this subchapter is
not required to pay a tax or assessment on its property or on any purchase
made by the association.

[**] Texas Medical Center Central Heating and Cooling Service Cooperative
Association (TECO) created under these provisions:
Subchapter B. Miscellaneous Cooperative Associations
Section 301.042 Tax Exemption
(a) A cooperative association created under this subchapter is not required to
pay a tax or assessment on its property or on any purchase made by the
association.

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