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Ezel / Tax Rulings / CT
CT Ruling 89-47 Sales and Use Taxes 1989-08-15

When were road or parking-lot grading services taxable under Connecticut Ruling 89-47?

Short answer: On industrial, commercial, or income-producing property, grading for new roads or parking lots was not taxable, but grading to repair or rebuild existing ones was taxable. Residential grading was not taxable whether new or repaired; landscaping was taxable. The ruling is obsolete.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 The official page says it was obsoleted by Announcement 94(4), so it is provided only as historical reference and should not be used as current authority.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 contractor's grading services for roads and parking lots under the law 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 contractor-service treatment.
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

For roads or parking lots on industrial, commercial, or income-producing real property, grading connected with new construction was not taxable under this ruling. Grading connected with repairing or rebuilding existing roads or parking lots was taxable.

For roads on residential property, grading was not taxable whether the work involved new roads or repair or rebuilding of existing roads.

The contractor said it performed road grading rather than landscaping. The ruling warned that landscaping services would be taxable.

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

What this means for you

The historical ruling made both the property's use and whether the work was new construction or repair important. It also treated grading and landscaping differently. Its obsolete status means current contractor classifications must be checked separately.

Common questions

Was grading for new commercial roads taxable? No, under this ruling.

Was grading to repair an existing commercial parking lot taxable? Yes.

Was residential road grading taxable? No, whether for a new road or repair or rebuilding.

Was landscaping treated the same as grading? No. The ruling said landscaping was taxable.

Citations and references

  • No statute or regulation was cited in the ruling text.

Source

Original ruling text

Ruling 89-47, Contractor

This Ruling has been obsoleted by AN 94(4)

Ruling 89-47

Contractor

To the extent that Taxpayer renders services in connection with the construction of new roads or parking lots, his grading services are not subject to sales and use taxes. To the extent that he renders services in connection with the repair or rebuilding of existing roads or parking lots, his grading ser- vices are subject to sales and use taxes.

This answer assumes that the roads or parking lots are situated on industrial, commercial or income-producing real property. To the extent that the roads are situated on residential property, Taxpayer's grading services are not subject to sales and use taxes, whether new roads or the repair or rebuilding of existing roads are involved.

Taxpayer has also indicated that his services involve road grading only and not landscaping. If this changes, his landscaping services will be subject to sales and use taxes.

LEGAL DIVISION

August 15, 1989

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