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Ezel / Tax Rulings / CT
CT Ruling 89-210 Petroleum Company Gross Earnings Tax 1989-11-14

Did selling petroleum products to a Connecticut municipality remove those receipts from the petroleum company gross earnings tax?

Short answer: No under this historical ruling. The tax applied to the petroleum company's gross receipts and was not required to be passed through with the company acting only as collector, so the customer's status as a Connecticut municipality did not change taxability.

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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 applying the petroleum company gross earnings tax to a petroleum company's sales to a Connecticut municipality. The result depended on the nature of that tax as imposed on the company's gross receipts rather than as a required customer pass-through; a different tax or transaction may be treated differently. 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

The petroleum company gross earnings tax applied to a petroleum company's gross receipts from sales of petroleum products. Unlike sales tax, it was not required to be passed through to customers with the petroleum company acting merely as the collector.

Because of that distinction, selling the petroleum products to a Connecticut municipality did not change the taxability of the company's gross receipts.

What this means for you

The customer's municipal status did not create an exemption from the petroleum company's own gross-receipts tax under this ruling.

Common questions

Were receipts from sales to a Connecticut municipality taxable? Yes.

Why did the municipality's status not matter? The tax was imposed on the petroleum company's gross receipts and was not required to be collected from the customer as a pass-through.

Citations and references

  • Texaco Refining & Marketing Co. v. Commissioner, 202 Conn. 583 (1987), as cited in the ruling.

Source

Original ruling text

Ruling 89-210, Petroleum Gross Earnings

Ruling 89-210

Petroleum Gross Earnings

The petroleum company gross earnings tax is imposed on a petroleum company's gross receipts from sales of petroleum products. Unlike the sales tax, the petroleum company gross earnings tax is not a tax that is required to be passed through to customers, with the petroleum company acting as a mere collector of the tax from its customers. See Texaco Refining & Marketing Co. v. Commissioner , 202 Conn. 583 (1987).

For this reason, the fact that a Connecticut municipality is the customer to which petroleum products are sold does not affect the taxability of the petroleum company's gross receipts derived therefrom.

LEGAL DIVISION

November 14, 1989

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