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Ezel / Tax Rulings / CT
CT Ruling 89-4 Sales and Use Taxes 1989-03-31

Were an economic expert's litigation-support services taxable in Connecticut under Ruling 89-4?

Short answer: No. The expert gathered and analyzed case data and presented opinions before a trier of fact for an attorney, rather than advising a business client. The services were not taxable business analysis or management services. The ruling is obsolete.

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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was obsoleted by Announcement 94(4), so it is provided only as historical reference and should not be used as current authority. It addressed one expert's attorney-retained litigation work under the service-tax rules then in effect. 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 current taxation of expert-witness and litigation-support services.
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 requester was hired and paid by attorneys to gather economic, financial, and business data relevant to cases, analyze it, form expert opinions, and present opinions and exhibits at depositions and trials.

Those services were not among the enumerated taxable services and did not fall within the cited definitions of business analysis or business management services.

The Department distinguished litigation testimony for an attorney before a trier of fact from giving conclusions and recommendations to a client about the client's business.

The official archive says the ruling was obsoleted by Announcement 94(4).

What this means for you

The historical ruling turned on the litigation purpose, the attorney as customer, and presentation to a trier of fact. Current tax treatment and materially different advisory work must be checked separately.

Common questions

Was the expert's work taxable? No.

Who hired and paid the expert? An attorney.

Why was it not business consulting? The work supported presentation before a trier of fact instead of recommendations about a client's business.

Citations and references

  • Conn. Agencies Regs. § 12-426-27(10)(a) and (b), as cited in the ruling.

Source

Original ruling text

Ruling 89-4, Consulting

This Ruling has been obsoleted by AN 94(4)

Ruling 89-4

Consulting

As we understand the facts, you are hired to and paid by an attorney. Your duties normally involve obtaining economic, financial and business data relevant to the case, analyzing the information to form expert opinions and presenting opinions and exhibits at depositions and at trial on economic and financial matters involved in the case.

It is our opinion that the services described above are not among the enumerated services subject to the sales and use tax and, more specifically, do not come within the definition of business analysis and business management services as defined in §12-426-27(10)(a) and (b) of the Regulations of Connecticut State Agencies. The reasoning behind this opinion is that your services are rendered to an attorney who hires you for presentation before a trier of fact, not for the purpose of giving conclusions and recommendations to a client about his business.

LEGAL DIVISION

March 31, 1989

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