[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-seo-304937-105":3,"detail-sidebar-cat-1-en-105":81,"doc-detail-304937-en":127},{"code":4,"msg":5,"data":6},0,"ok",{"site_id":7,"language":8,"slug":9,"title":10,"keywords":11,"description":12,"schema_data":13,"social_meta":74,"head_meta":76,"extra_data":78,"updated_unix":80},105,"en","tsb-a-9720s-sales-tax-advisory-opinion-petition-s960923a","TSB-A-97(20)S Sales Tax - Advisory Opinion - Petition S960923A","","New York State Department of Taxation and Finance issues an advisory opinion addressing sales tax questions raised in Petition No. S960923A. The petition concerns whether merchandise sales to organizations exempt under Tax Law Sections 1116(a)(1) and (4) qualify for exemption when purchases are made by members using Costco Wholesale membership models. The opinion details business vs. Goldstar memberships, membership card identifiers, invoicing practices, and the documentation presented for exemption requests. It analyzes scenarios where individuals with Goldstar memberships attempt to purchase for exempt organizations using limited authorization documents, without traditional purchase orders.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/template/","Template",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/template/forms/","Forms",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/template/tsb-a-9720s-sales-tax-advisory-opinion-petition-s960923a/304937/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/tsb-a-9720s-sales-tax-advisory-opinion-petition-s960923a/304937.png","ImageObject",442,249,{"name":42,"@type":43},"Chloe Bennett","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-09-29","2026-09-19",true,{"@type":52,"interactionType":53,"userInteractionCount":55},"InteractionCounter",{"@type":54},"ViewAction",7,{"@type":57,"mainEntity":58},"FAQPage",[59,65,69],{"name":60,"@type":61,"acceptedAnswer":62},"What sales tax issues does Petition No. S960923A raise?","Question",{"text":63,"@type":64},"The petition raises questions about whether sales of merchandise qualify for sales and compensating use tax exemptions for organizations exempt under Tax Law Sections 1116(a)(1) and (4).","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"How do Business Memberships and Goldstar Memberships differ in the petition?",{"text":68,"@type":64},"Business Memberships are issued in the name of the underlying entity and support exemptions after qualifying information is provided, while Goldstar Memberships are stand-alone individual memberships generally not extended sales tax exemptions under the described rule of practice.",{"name":70,"@type":61,"acceptedAnswer":71},"What documentation situations are described for attempted exemptions when a Goldstar member purchases for an exempt organization?",{"text":72,"@type":64},"The text describes scenarios including a completed Exempt Organization Certification without purchase order documentation, and later a letter authorizing the purchase on behalf of the organization, with the letter kept with sales records for the applicable petitioner.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},304937,1790442501,{"code":4,"msg":82,"data":83},"success",[84,89,94,99,104,109,113,118,123],{"id":85,"doc_module":22,"doc_module_name":25,"category_name":86,"show_sort_weight":87,"slug":88},11,"Presentations",90,"presentations",{"id":90,"doc_module":22,"doc_module_name":25,"category_name":91,"show_sort_weight":92,"slug":93},12,"Resumes",80,"resumes",{"id":95,"doc_module":22,"doc_module_name":25,"category_name":96,"show_sort_weight":97,"slug":98},14,"Invoices",70,"invoices",{"id":100,"doc_module":22,"doc_module_name":25,"category_name":101,"show_sort_weight":102,"slug":103},15,"Posters",60,"posters",{"id":105,"doc_module":22,"doc_module_name":25,"category_name":106,"show_sort_weight":107,"slug":108},16,"Social Media",50,"social-media",{"id":110,"doc_module":22,"doc_module_name":25,"category_name":29,"show_sort_weight":111,"slug":112},17,40,"forms",{"id":114,"doc_module":22,"doc_module_name":25,"category_name":115,"show_sort_weight":116,"slug":117},18,"Letters",30,"letters",{"id":119,"doc_module":22,"doc_module_name":25,"category_name":120,"show_sort_weight":121,"slug":122},21,"Paper Templates",5,"papers-templates",{"id":124,"doc_module":22,"doc_module_name":25,"category_name":125,"show_sort_weight":4,"slug":126},158,"General","general-158",{"code":4,"msg":82,"data":128},{"doc_id":79,"user_id":129,"nickname":42,"user_avatar":130,"doc_module":22,"category_id":110,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":55,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":136,"language":137,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":138,"faqs":139,"seo_title":140,"seo_description":12,"update_tm":141,"read_time":30},962084925782,"https://ap-avatar.wpscdn.com/davatar_9964176cb1d06d4a9deccf72a44ae3dc","New York State Department of Taxation and Finance Taxpayer Services Division Technical Services Bureau  \nTSB-A-97(20)S Sales Tax  \nSTATE OF NEW YORK  \nCOMMISSIONER OF TAXATION AND FINANCE  \nADVISORY OPINION  PETITION NO . S960923A  \nOn September 23, 1996, the Department of Taxation and Finance received a joint Petition for Advisory Opinion from Costco Wholesale Corporation and The Price Co . , Inc . , 999 Lake Drive, Issaquah, Washington 98027. Petitioners, Costco Wholesale Corporation and The Price Co . , Inc . , provided additional information pertaining to the Petition on October 15, 1996.  \nThe issues raised by Petitioners concern sales of merchandise to organizations that are exempt from State and local sales and compensating use taxes under Sections 1116(a)(1) and (4) of the Tax Law .  \nPetitioners submitted the following facts as the basis for this Advisory Opinion .  \nPetitioners are in the membership warehouse segment of specialty retailing. Their physical operations are almost identical . They operate cash and carry membership warehouses in over 20 states and in various international markets including Canada . Combined, they have over ten locations in New York State . Petitioners service both the retail and wholesale markets .  \nPetitioners sell a variety of merchandise including: food, candy, tobacco, sundries, appliances, electronics, tools, office supplies, furniture, automotive supplies, apparel, linens, jewelry, housewares, books, optical items, and prescription and over-the-counter medicines . Most of Petitioners’ New York sales are cash and carry with the purchasers taking possession of the merchandise at Petitioners’ registers in this State .  \nPetitioners do not require nor do they use any form of sales contracts, purchase orders or other sales instructions . Sales are strictly cash and carry with the only invoices being standard cash register receipts . While the receipts show membership numbers ( infra ), they are otherwise devoid of any names, addresses or other identification of the purchasers .  \nOnly members who have paid membership fees and obtained membership identification cards are allowed access to Petitioners’ warehouse facilities . Petitioners offer two types of memberships: Business Memberships and Goldstar (individual) Memberships . These memberships are equivalent to accounts . The membership records contain the names, addresses and phone numbers of members . For Business members, these records also include any New York State registration or exemption numbers furnished by the members when they initially sign up as members .  \nBusiness Memberships are available to businesses, nonprofit organizations and state or local governmental entities . A Business Membership is issued in the name of the underlying entity . With each Business Membership there is one\"primary\" cardholder who is responsible for the membership account . In addition to the primary member, there may be an unlimited number of \"add-on\" members; however, Petitioners discourage more than six add-ons per primary member . Unique membership numbers are issued to each primary and add-on member . Each member is issued a membership card showing his or her unique membership number, the name  \n-2  \nTSB-A-97(20)S Sales Tax  \nof the underlying entity, the name of the individual member and a photo ID of the individual to whom the membership card is issued . A Business member may shop for either business or personal needs . Payments may be made with either business or personal funds using company or personal checks, credit cards or cash . The Business Membership fee is $30 annually .  \nGoldstar Memberships are available to individuals who are members of certain eligible groups, such as employees of state, local and federal governments, schools, hospitals, banks, public utilities and other eligible groups . These individual memberships are stand alone memberships and are not directly associated with the qualified group . For example, an individu","cbCain9uij6C8srU","https://ap.wps.com/l/cbCain9uij6C8srU","pdf",36990,9,"English","# Advisory Opinion\n## Petition No. S960923A\n## Issues Under Tax Law Sections 1116(a)(1) and (4)\n## Membership Models and Documentation Scenarios","[{\"question\":\"What sales tax issues does Petition No. S960923A raise?\",\"answer\":\"The petition raises questions about whether sales of merchandise qualify for sales and compensating use tax exemptions for organizations exempt under Tax Law Sections 1116(a)(1) and (4).\"},{\"question\":\"How do Business Memberships and Goldstar Memberships differ in the petition?\",\"answer\":\"Business Memberships are issued in the name of the underlying entity and support exemptions after qualifying information is provided, while Goldstar Memberships are stand-alone individual memberships generally not extended sales tax exemptions under the described rule of practice.\"},{\"question\":\"What documentation situations are described for attempted exemptions when a Goldstar member purchases for an exempt organization?\",\"answer\":\"The text describes scenarios including a completed Exempt Organization Certification without purchase order documentation, and later a letter authorizing the purchase on behalf of the organization, with the letter kept with sales records for the applicable petitioner.\"}]","TSB-A-97(20)S Sales Tax - Advisory Opinion - Petition S960923A | PDF",1789819831]