Fractional Texas sales & use tax support for accounting firms — written answers with citations, contract and invoice reviews, and audit-notice support, from someone who ran these audits for the Comptroller. Behind the scenes, white-label, or client-facing when you want. Flat monthly fee. You stay the client-facing firm.
You do income tax, the books, CAS, the CFO work. Texas sales & use tax is its own system — taxability of products and services, bundled charges, contractor labor rules, SaaS and data processing, marketplace and e-commerce questions, use tax exposure, invoice language that quietly creates exposure. When a client asks, the honest options today are over-research it, guess, or say "ask the Comptroller."
Meanwhile your CAS and fractional CFO engagements build the invoices and billing systems where sales tax errors are born. When one of those clients gets audited, the question becomes: who set this up?
The desk gives you a fourth option: send it to a specialist who worked the other side of these audits, get a written answer with citations in days, and deliver it under your brand. For a taste of the patterns I look for, start with the 7 Texas sales tax mistakes hiding in your clients' contracts and invoices.
The desk is how most firms work with me: a flat monthly fee, questions answered in writing, and a specialist your clients can be told about. Month-to-month, cancel anytime.
A test-drive of the Partner Desk: up to 3 client-specific questions plus one partner call. We put a decision call on the calendar for day 25; if you continue, the pilot rolls straight into your Partner Desk membership on day 31 and the $750 comes off month one — so the trial is effectively free. Fair warning, stated up front: if you send fewer than two questions in the month, I'll tell you the desk isn't for you.
Not ready for a membership? One-off desk questions are a fixed $350 each, answered as capacity allows — members come first. A desk question is one fact pattern for one client, up to an hour of my time, answered in writing for your firm's internal use; anything client-facing in writing, or anything requiring document review, becomes a quoted project — and I say so before doing the work, never after. Desk seats are capped so turnaround stays honest. Founding-firm offer: the first 10 firms lock 20% off their tier for 12 months.
| What you get | One-off | Essential | Priority | Partner Desk | Fractional |
|---|---|---|---|---|---|
| Desk questions | $350 each | 1 per month | 2 per month | 6 per month | 12 per month |
| Written, citation-backed answers | ✓ | ✓ | ✓ | ✓ | ✓ |
| Unused questions roll 90 days | — | ✓ | ✓ | ✓ | ✓ |
| Front-of-queue turnaround | — | — | ✓ | ✓ | ✓ |
| Audit-notice priority for your clients | — | — | ✓ | ✓ | ✓ |
| Quarterly client-ready bulletin | — | — | ✓ | ✓ | ✓ |
| Annual book-scan call | — | — | ✓ | ✓ | ✓ |
| Monthly advisory call | — | — | — | 60 min | 2 calls |
| Light review of invoices & certificates | — | — | — | ✓ | ✓ |
| Monthly practical memo | — | — | — | ✓ | ✓ |
| Staff training | — | — | — | Quarterly | Program |
| Member pricing on project work | — | ✓ | ✓ | ✓ | Preferred |
| Client-facing call support | — | — | — | — | ✓ |
| Price | $350 / question | $299 / mo | $499 / mo | $1,500 / mo | from $3,000 / mo |
If your book only hits Texas sales tax a couple of times a year, skip the subscription and send one project. The flagship is the Contract / Service Agreement Review: send a client's contract, invoice set, or order forms, get back a written findings memo — issue, treatment, citation, recommended fix — deliverable under your firm's brand. Audit-notice response packages, taxability memos, and staff training sessions are also available à la carte.
One short agreement, service contract, or invoice set with limited complexity.
One primary agreement plus related invoices, order forms, or billing examples.
Multiple agreements or revenue streams, bundled transactions, SaaS/software/data issues, multi-location activity, or higher audit exposure.
Pricing starts at $750 and depends on the number of agreements, revenue streams, transaction types, invoices, entities, locations, and whether a written memo is needed. The tier is confirmed and quoted up front after a quick look at the documents — then it's fixed. No hourly meter. Partner Desk members pay $600 / $1,250 / $2,500.
Your staff emails the desk a question or uploads a client contract or invoice set. Tag it "question" or "review." A quick conflicts check runs on every new client name.
Questions come back as a short written memo — treatment, authority, caveats. Reviews come back as a findings memo with recommended fixes. Everything cites the rule, publication, or statute.
You present the answer under your brand, marked up or bundled into your advisory fee however you like. Your client never sees my invoice — or me, unless you want a joint call.
The services agreement includes a written no-solicitation covenant: I will not solicit or accept direct engagement from your clients without your written consent. Deliverables are addressed to your firm. If one of your clients lands in a full Comptroller audit and you want to hand them to me directly for Frontline Audit Defense, that's your call — and you stay in every email, because transparent representation is how I already work.
I'm Patrick Fulker. I ran sales tax audits for the Texas Comptroller and spent nearly six years inside the agency — first as a field auditor, later as the agency's internal IT auditor. Now I run a solo practice doing exactly one thing: Texas sales & use tax — product sellers, service businesses, contractors, SaaS and software, e-commerce, multi-location operations, and companies facing Comptroller audit issues.
That focus is the point. I'm not a CPA and don't want your compliance work. I don't do income tax, franchise tax, or anything federal — and I refer that work to firms like yours. I also don't do multi-state work: if a question is about another state's tax, I'll tell you fast and point you to someone who does it well. The desk only works if you never have to wonder whose client it is — or whose lane I'm in.
Reviews look at your client's documents the way the Comptroller's auditor will — sampling exposure, invoice language, the contract-versus-billing mismatch that drives assessments.
Every answer cites the Tax Code, Administrative Code rule, or Comptroller publication it rests on — so your file shows diligence, not a hallway opinion.
Published pricing, quoted up front, fixed once quoted. The same transparency promise my audit-defense clients get.
$1M E&O coverage with a sales-tax-consulting endorsement, and a conflicts screen on every client name against my former audit assignments.
No — and you don't have to take my word for it. The services agreement includes a no-solicitation covenant: I won't solicit or accept direct engagement from your clients without your written consent. This channel only works for me if firms trust it completely; poaching one client would cost me the whole model.
Texas sales & use tax consulting isn't a CPA-licensed activity, and the Comptroller explicitly authorizes non-CPA, non-attorney representatives (Form 01-137). What I bring is the thing a license doesn't cover: years running these exact audits for the Comptroller. Your firm keeps professional responsibility to your client and decides what to adopt — I'm your specialist subcontractor, the same way you'd use an outside valuation or IT-audit shop.
No. The review is limited to Texas sales and use tax treatment. It's not a legal review of contract enforceability, liability, indemnity, employment law, collections, or other non-tax legal matters — and I flag it when a question needs an attorney.
One discrete fact pattern for one client, up to an hour of my time — "my client invoices lump-sum for commercial HVAC replacement; taxable?" is one question. Desk answers are written guidance for your firm's internal use; anything client-facing in writing, or anything requiring real document review, is a quoted project — and I say so before spending your hour, never after. If a question is really a contract review in disguise, I'll quote the review instead of burning your question allowance on half an answer. Unused questions roll forward for 90 days.
Yes. Memos are addressed to your firm, and on the Partner Desk and Fractional Department tiers I produce client-ready versions you can put on your own letterhead. You control the markup; your client never sees my fee.
I stay in my lane: Texas sales & use tax only. One distinction worth knowing: whether an out-of-state seller has Texas nexus — economic nexus thresholds, marketplace facilitator rules, inbound sellers — is Texas law, and squarely in scope. A 50-state nexus study is not; for multi-state work I'll tell you plainly it's out of scope and point you to the right kind of specialist.
Send it to the desk same-day — members get priority. The Audit Notice Response Package covers the notice review, what the auditor will request and why, document-request prep, and a briefing memo your staff can work from. One honest boundary: I can support your firm behind the scenes through the document stages, but if it escalates to communicating with the Comptroller on the client's behalf, that's named-representative work — audit defense is the one thing I can't do invisibly, and you don't want it done invisibly. It becomes a direct engagement at my published fixed fees, with your firm copied on every piece of correspondence.
Yes, as a research and quality-control aid. I use Anthropic's Claude (and occasionally OpenAI) to cross-reference Texas tax authority and to surface issues I might miss on my own. Client data is processed under business API agreements that don't train on your data and don't retain it after each request. I personally review and stand behind every word of the work product I deliver. If your firm prefers I work entirely without AI assistance, just let me know.
Send me one sales tax question or client fact pattern your firm ran into recently — I'll give you a written read on it, free. Or take fifteen minutes to see whether the desk fits your book.
Book a 15-minute intro callA sentence or two about your firm and the kinds of clients you serve is plenty. I reply personally, usually within one business day.
Prefer email? Reach me directly at patrick@frontlinesalestax.com.