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Ezel / Tax Rulings / CT
CT Ruling 89-249 Sales and Use Taxes 1989-12-05

Were Company X's tour receipts taxable, and how were its purchases used to provide the tours treated?

Short answer: The tour receipts were not subject to sales and use tax under this historical ruling. Company X was the final consumer of purchases used to perform the tours and had to pay applicable sales tax and/or admissions tax on those purchases. DRS says AN 94(7) obsoleted the ruling.

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 tour-service rules then in effect. DRS expressly says Announcement (AN) 94(7) obsoleted it. The short text does not describe the tours or the provider's purchases, so its treatment should not be extended to different tour, admission, transportation, or bundled charges. 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 -- obsolete historical guidance. DRS states that this ruling was obsoleted by Announcement (AN) 94(7).

Plain-English summary

DRS ruled that Company X's total gross receipts from providing tours were not subject to sales and use tax.

Company X was nevertheless the final consumer of everything it bought to perform the tour services. It therefore had to pay the applicable sales tax and/or admissions tax on those purchases.

What this means for you

The historical ruling separated the customer's tour charge from the provider's own inputs: the tour receipts were not taxed, but the provider owed applicable tax as consumer of its purchases. AN 94(7) later obsoleted the guidance.

Common questions

Were the tour receipts taxable? No under the ruling.

Could Company X buy its service inputs for resale? The ruling says Company X was the final consumer of all purchases used to perform the service.

What tax applied to those purchases? Applicable sales tax and/or admissions tax.

Citations and references

  • Announcement (AN) 94(7) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-249, Advertising

This Ruling has been obsoleted by AN 94(7)

The total gross receipts for the tours provided by Company X are not subject to sales and use tax. Company X is the final consumer of all purchases it makes in performing its services and must pay the applicable sales tax and/or admissions tax on said purchases.

LEGAL DIVISION

December 5, 1989

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