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Ezel / Tax Rulings / CT
CT Ruling 89-136 Sales and Use Taxes 1989-10-10

Did apple refrigeration equipment and a replacement compressor qualify for Connecticut's agricultural-production exemption?

Short answer: Yes under this historical ruling. Refrigerating apples to prevent deterioration was direct use in agricultural production, so the replacement compressor qualified for a sales-and-use-tax refund. The ruling also cited a farmer-purchase exemption effective October 1, 1989. DRS says AN 94(5) partly obsoleted it.

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 reflecting the agricultural-production machinery exemption then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(5) obsoleted it in part. Its result concerns refrigeration used to prevent apple deterioration, a replacement compressor, and the farmer-purchase exemption in Public Act No. 89-123 effective October 1, 1989. 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 your specific situation.
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)

Note -- partially obsolete historical guidance. DRS marks this information "not current" and states that Announcement (AN) 94(5) obsoleted the ruling in part.

Plain-English summary

Refrigerating apples to prevent deterioration was exempt machinery used directly in agricultural production. A compressor purchased to replace the refrigerator's old compressor therefore qualified for a refund of sales and use tax.

The ruling also stated that Public Act No. 89-123 exempted tangible personal property purchased by farmers for exclusive use in agricultural production, effective October 1, 1989.

What this means for you

The historical result treated refrigeration that prevented apple deterioration as direct agricultural production and extended that treatment to the replacement compressor. AN 94(5) later obsoleted the ruling in part.

Common questions

Was apple refrigeration exempt machinery? Yes when used to prevent deterioration.

Did the replacement compressor qualify for a refund? Yes.

What farmer-purchase rule did the ruling mention? An exemption for tangible personal property bought by farmers for exclusive use in agricultural production, effective October 1, 1989.

Citations and references

  • Public Act No. 89-123, as cited in the ruling.
  • Announcement (AN) 94(5) -- identified by DRS as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-136, Machinery

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

This Ruling has been obsoleted in part by AN 94(5)

Refrigeration of apples to prevent deterioration is exempt machinery used directly in agricultural production. The purchase of a compressor to replace the old compressor in the refrigerator qualifies for a refund of sales and use tax.

Public Act No. 89-123 provides a sales and use tax exemption for purchases of tangible personal property by farmers for exclusive use in agricultural production effective October 1, 1989.

TIMOTHY F. BANNON

COMMISSIONER

October 10, 1989

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