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Ezel / Tax Rulings / CT
CT Ruling 89-172 Sales and Use Taxes 1989-10-30

Were licensed engineers' motor-vehicle accident-reconstruction receipts, including separately stated photos, subject to Connecticut sales tax?

Short answer: No under this historical ruling. Total accident-reconstruction receipts, including separately stated photographs and prints, were not taxable. The engineer was the final consumer of film, photos, prints, and development and owed sales or use tax on those inputs.

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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 addressing licensed engineers' motor-vehicle accident-reconstruction services and related photographs. Its result depended on the photos being part of the engineering service and treated the engineer as final consumer of all materials and supplies; different products or services may be treated differently. 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)

Plain-English summary

A licensed professional engineer reconstructed motor-vehicle accidents as an expert witness for attorneys, police departments, and insurance companies and provided photographs and prints of accident scenes as part of the service.

DRS said total accident-reconstruction receipts were not taxable, including separately stated photo and print charges. The engineer was the final consumer of film, photographs, prints, and development and had to pay sales or use tax on those purchases.

What this means for you

The historical ruling treated the photos as part of the engineering service while taxing the engineer's material inputs.

Common questions

Were accident-reconstruction receipts taxable? No under the ruling.

Were separately stated photos and prints taxable? No.

Who owed tax on film and development costs? The engineer as final consumer.

Citations and references

  • The published ruling text does not cite a specific statute or regulation.

Source

Original ruling text

Ruling 89-172, Consulting

According to the information presented in your letter, you render a professional engineering service whereby you reconstruct motor vehicle accidents as an expert witness for attorneys, state and local police departments and insurance companies. X Company furnishes photographs and prints of the accident scenes to their clients as part of the engineering service to reconstruct motor vehicle accidents.

The total gross receipts for the reconstruction of motor vehicle accidents by licensed professional engineers, inclusive of separately-stated fees for the photographs and prints of the accident scene, are not subject to sales and use tax. The engineer is the final consumer of all materials and supplies, e.g., film, photographs, prints and development costs, used in performing his services and must pay sales or use tax on said purchases.

LEGAL DIVISION

October 30, 1989

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