Tax Type
Retail Sales and Use Tax
Description
School purchase of meals and lodging
Topic
Taxability of Persons and Transactions
Date Issued
11-01-1989
November 1, 1989
Re: Ruling Request/Sales and Use Tax
Dear******************
This will reply to your letter of October 16, 1989 seeking an exemption from the sales and use tax for the ************** ("the Taxpayer").
FACTS
The Taxpayer is an organization closely affiliated with***********("the University"), whose sole purpose is to foster the growth and development of the University, an educational organization within the meaning of Internal Revenue Code §170(b)(1)(A)(ii). In connection with a conference scheduled for early November, 1989 in the mid-Atlantic region, the Taxpayer seeks an exemption from the sales and use tax.
RULING
Based on the documentation provided, I find no basis in Virginia law for the exemption requested by the Taxpayer. Even purchases by the University itself of rooms and lodging would be taxable in most instances, in accordance with the enclosed July 28, 1989 ruling. It should be noted further that purchases of rooms and lodging by state and local government units, including state colleges and universities, using government funds, are generally taxable.
If you have any further questions, please let me know.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner