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Ezel / Tax Rulings / CT
CT Ruling 89-237 Sales and Use Taxes 1989-11-22

Which fabrication, installation, component-part, fixture, and repair charges were taxable under Connecticut Ruling 89-237?

Short answer: Fabricated brackets, supplemental production-machinery parts, fixtures, and tangible-personal-property repairs were taxable on their full receipts, including labor and materials. Bracket installation was not taxable only when separately stated.

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 applying the fabrication, installation, component-part, fixture, and repair rules then in effect. The results depend on the particular charges described, including whether bracket installation was separately itemized; another taxpayer should not assume the same treatment for different work or billing. 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

DRS treated the full receipts from fabricated brackets as taxable, including fabrication labor and materials. A separately stated charge to install the bracket on the chipper was not taxable, but the installation charge became taxable when it was not separately itemized.

The full receipts from component parts that supplemented production machinery and from fixtures were also taxable. Repairs to tangible personal property were taxable on the entire sales price, including repair labor and parts.

What this means for you

Under this ruling, separately stating the bracket-installation charge changed its treatment. Fabrication, component-part, fixture, and tangible-personal-property repair charges remained taxable as described.

Common questions

Were fabricated brackets taxable? Yes, including fabrication labor and materials.

Was bracket installation taxable? Not when separately stated; otherwise, the installation charge was taxable.

Were repairs to tangible personal property taxable? Yes, including repair labor and repair parts.

Were supplemental production-machinery parts and fixtures taxable? Yes, on total gross receipts including fabrication labor and materials.

Citations and references

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

Source

Original ruling text

Ruling 89-237, Repairs

The total gross receipts, inclusive of fabrication labor and materials, for the sales of a "fabricate bracket" are subject to sales and use tax. A separately-stated charge for installation of the bracket onto the chipper fee is not taxable. The installation fee is applicable to the tax if it is not separately itemized on the bill.

The total gross receipts, inclusive of fabrication labor and material, for the sales of component parts which supplement production machinery are subject to the sales and use tax.

The total gross receipts, inclusive of the fabrication labor and materials, for the sales of fixtures are subject to sales and use tax.

The sales and use tax applies to the total sales price for repairs to tangible personal property including charges for repair labor and repair parts.

LEGAL DIVISION

November 22, 1989

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