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Ezel / Tax Rulings / CT
CT Ruling 89-187 Sales and Use Taxes 1989-10-31

When were forensic pipe inspections and industrial-equipment failure analysis taxable under Connecticut Ruling 89-187?

Short answer: Pipe inspections in existing commercial, industrial, or income-producing buildings were taxable; inspections in new construction or qualifying owner-occupied one- to three-family homes were not. Industrial-equipment failure analysis and inspection were exempt. DRS says SN 95(17) partly superseded it.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 forensic-engineering service rules then in effect. DRS expressly marks the information 'not current' and says Special Notice (SN) 95(17) superseded it in part. Its outcomes depended on the property inspected, new construction, qualifying residential occupancy, and pipe versus industrial-equipment work. 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Note -- partially superseded historical guidance. DRS marks this information "not current" and states that Special Notice (SN) 95(17) superseded the ruling in part.

Plain-English summary

Forensic-engineering inspections of pipes in existing commercial, industrial, or income-producing buildings were taxable when performed to measure corrosion, estimate remaining pipe life, or evaluate water-treatment programs.

Pipe inspections in new construction or in exclusively residential owner-occupied one-, two-, or three-family homes were not taxable. Total receipts from failure analysis and inspection of industrial equipment were also exempt under the ruling.

What this means for you

The historical classification turned on both the inspected property and the type of forensic work. SN 95(17) later superseded the guidance in part.

Common questions

Were pipe inspections in existing commercial buildings taxable? Yes.

Were pipe inspections in new construction taxable? No.

Were pipe inspections in qualifying owner-occupied homes taxable? No.

Was industrial-equipment failure analysis taxable? No under the ruling.

Citations and references

  • Special Notice (SN) 95(17) -- identified by DRS as partly superseding this ruling.

Source

Original ruling text

Ruling 89-187, Engineering

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

Ruling 89-187

Engineering

This Ruling has been superseded in part by   SN 95(17)

Forensic engineering services that involve the inspections of pipes in existing commercial, industrial or income-producing buildings to determine the corrosion rate, estimate the remaining life of the piping systems and/or determine the effectiveness of water treatment programs are subject to sales and use tax.

Inspections of pipes performed in new construction or in one, two or three family, exclusively residential owner-occupied homes are not taxable.

The total gross receipts for forensic engineering services rendered whereby you conduct failure analysis and inspection services on industrial equipment are exempt from sales and use tax.

LEGAL DIVISION

October 31, 1989

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