Tax Type
Retail Sales and Use Tax
Description
Research and development; High definition television
Topic
Taxability of Persons and Transactions
Date Issued
09-13-1990
September 13, 1990
Re: Request for Ruling/Sales and Use Tax
Dear***************
This will reply to your letter of August 17, 1990 in which you request further consideration for a sales and use tax exemption for**************** (the Taxpayer).
In light of the additional information provided by your letter, and the information provided by******** in the meeting with members of my staff on August 3, 1990, I find basis for extending the research and development exemption to that equipment used by the Taxpayer for the testing of "Advanced television" and "High definition television". As provided by my letter of August 1, 1990 (copy enclosed), the research and development exemption was previously extended to the "terrestrial spectrum bands" testing.
The exemption is limited, however, to tangible personal property used directly and exclusively in qualifying research activities. As noted in Virginia Regulation §630-10-92 (copy enclosed), property that is used both in taxable and exempt activities is deemed to be fully taxable due to the exclusive use requirement.
If you should have any further questions, please feel free to contact the department.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner