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Ezel / Tax Rulings / CT
CT Ruling 89-104 Sales and Use Taxes 1989-09-26

Did Connecticut Ruling 89-104 impose sales tax on land-planning and zoning-related services?

Short answer: No. The listed land-planning services were nontaxable, including zoning studies, meeting representation, maps not included in land surveying, and land-use reports. DRS says AN 94(3) obsoleted the ruling.

Apply this to your situation

This page answers the general question as of 1989. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1989
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official 1989 Connecticut Department of Revenue Services Ruling, but its page expressly says the information is not current and that AN 94(3) obsoleted the ruling. It is presented only as historical reference and should not be used as current law. Connecticut imposes sales and use tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current treatment.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

The ruling treated the listed land-planning services as nontaxable: land evaluation, zoning-regulation studies, planning and development studies, representation at zoning meetings, zoning and proposal maps, and reports on land use.

The map conclusion applied only when the maps were not part of land-surveying services.

The official page says this information is not current and that AN 94(3) obsoleted the ruling.

What this means for you

The ruling's historical treatment depended on the work being land planning, with an express limitation for maps included in land surveying. Because DRS marks the ruling obsolete, current planning and surveying engagements require current guidance.

Common questions

Were land evaluations and zoning studies taxable? No under the ruling.

Were zoning-meeting representation and land-use reports taxable? No.

Were zoning and proposal maps always nontaxable? No. The ruling limited its answer to maps that were not part of land-surveying services.

Is the ruling current? No. AN 94(3) obsoleted it.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as amended by Public Act No. 89-251, as cited in the ruling.
  • AN 94(3), identified by the official page as obsoleting this ruling.

Source

Original ruling text

Ruling 89-104, Engineering

This information is not current and is being provided for reference purposes only

This Ruling has been obsoleted by AN 94(3)

Land planning services, such as land evaluation, zoning regulation study, planning and development study, representation at zoning meetings, zoning maps and proposal maps (as long as such maps are not part of land surveying services), and reports on land usage are not subject to the sales tax under section 12-407(2)(i)(F), as amended by Public Act No. 89-251.

LEGAL DIVISION

September 26, 1989

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