Tax Type
Retail Sales and Use Tax
Description
Government transactions; College horse riding center
Topic
Taxability of Persons and Transactions
Date Issued
06-23-1993
June 23, 1993
Re: Request for Ruling: Retail Sales and Use Tax
Dear**************
This is in response to your letter of June 1, 1993 in which you seek a ruling regarding the application of the retail sales and use tax to purchases by *********(the College).
FACTS
The College, a nonprofit institution, operates a riding center as part of its educational program. Students have access to the riding center for college credit under the College's physical education program and may also participate on the College's intercollegiate riding team.
One of the suppliers used by the riding center was recently audited by the department, and that supplier has indicated that it cannot sell certain tangible personal property to the College exempt of the tax. In making this claim, the supplier relied on the regulations which govern agricultural purchases made by farmers.
RULING
Virginia Regulation (VR) 630-10-96 provides that:
-
- The tax does not apply to sales of tangible personal property to nonprofit schools, colleges and other institutions of learning for their use or consumption and paid for out of their funds.
- The tax does not apply to sales of tangible personal property to nonprofit schools, colleges and other institutions of learning for their use or consumption and paid for out of their funds.
Furthermore, I understand that the department's*********District Office has contacted the College's supplier and explained that sales to the College may be made exempt of the tax as governed by the educational exemption discussed above.
I trust that this information addresses your concerns, but please contact the department if you have any additional questions.
Sincerely,
W. H. Forst
Tax Commissioner
OTP/7044I
Rulings of the Tax Commissioner