9702248L

February 10, 1997

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Dear **************:

Your letter requesting to use the coupon system has been forwarded to my desk 
for reply.

The coupon system that you propose is one where coupons are sold for $1 each 
and later redeemed for various alcoholic beverages.  The club will account for 
the number of units and dollar amount for each class of beverage (liquor, beer, 
and wine) purchased with a coupon.  You will also account for, separately, 
coupons redeemed for different priced drinks, such as bar or call drinks.  The 
daily summary will show, by class of beverage, alcoholic beverages sold at 
regular prices and those served by redeeming coupons. 

The coupon system that you described using for tournaments and large parties is 
approved.  

The mixed beverage gross receipts tax should be reported and paid on the 
coupons that are redeemed or used [Comptroller Rule 3.1001(c)(11)] for the 
service of an alcoholic beverage and not on the number of coupons sold.    

This opinion is based on the facts presented.  If there are additional or 
different facts, the opinion may change.

If I can be of further help, please call me at 1/800-531-5441, extension 
3-3849, toll-free.  The regular number is 512/463-3849.  You may also write me 
at Tax Policy Division or Fax 512/475-0900.

Sincerely,
Kirk J. Davenport
Tax Policy Division

ACCESSION NUMBER: 9702248L
SUPERSEDED: N
DOCUMENT TYPE: L
DATE: 02/10/1997
TAX TYPE: BEVERAGE