Private Letter Ruling

Ruling Number:P-1999-242
Tax Type:Kansas Compensating Tax; Kansas Retailers' Sales Tax
Brief Description:Direct purchases by hospitals.
Approval Date:10/29/1999

Office of Policy & Research

October 29, 1999


I have been asked to respond to your letter dated September 15, 1999.

In your letter, you stated:

K.S.A. 79-3606(b) exempts from Kansas retailers’ sales tax: “all sales of tangible personal property or service, including the renting and leasing of tangible personal property purchased directly by. . .a public or private nonprofit hospital. . .and used exclusively for. . .hospital. . .purposes, except when: (1) Such. . .hospital is engaged or proposes to engage in any business specifically taxable under the provisions of this act and such items of tangible personal property or service are used or proposed to be used in such business,. . .”

Based on the facts as contained in your letter, it is the opinion of the Kansas Department of Revenue that the described transaction is a direct purchase by the hospital and is exempt from Kansas sales and compensating tax pursuant to K.S.A. 79-3606(b).

This is a private letter ruling pursuant to K.A.R. 92-19-59. It is based solely on the facts provided in your request. If it is determined that undisclosed facts were material or necessary to an accurate determination by the department, this ruling is null and void. This ruling will be revoked in the future by the operation of law without further department action if there is a change in the statutes, administrative regulations, or case law, or published revenue ruling, that materially affects this private letter ruling.


Mark D. Ciardullo
Tax Specialist

Date Composed: 11/03/1999 Date Modified: 10/10/2001