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Ezel / Tax Rulings / CT
CT Ruling 89-75 Sales and Use Taxes 1989-09-06

Did Connecticut Ruling 89-75 exempt electricity and gas used by greenhouse and nursery florists?

Short answer: Yes, when the utilities were used directly in greenhouse or nursery agricultural production. Florists that merely bought cut flowers and made arrangements owed tax on their utility bills. PS 94(3) obsoleted the ruling.

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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, but its page expressly says the information is not current and that PS 94(3) obsoleted the ruling. It is presented only as historical reference and should not be used as current law. 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 agricultural utility exemptions.
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

Electricity and gas used directly in agricultural production were exempt under the historical ruling. That included utilities sold to florists operating greenhouses and nurseries because those operations fell within the agricultural exemption.

The exemption did not cover florists that bought cut flowers and prepared floral arrangements. Their utility bills were taxable.

The official page says the information is not current and PS 94(3) obsoleted the ruling.

What this means for you

The historical distinction turned on producing plants in a greenhouse or nursery rather than arranging flowers purchased from others. Because the ruling is obsolete, current utility purchases require current guidance.

Common questions

Were greenhouse and nursery utilities exempt? Yes, when used directly in agricultural production.

Were utilities used to arrange purchased cut flowers exempt? No. Those utility bills were taxable.

Citations and references

  • PS 94(3), identified by the official page as obsoleting this ruling.

Source

Original ruling text

Ruling 89-75, Utility Exemption - Agricultural

This information is not current and is being provided for reference purposes only

This Ruling has been obsoleted by PS 94(3)

The sales of electricity and gas used directly in agricultural production are exempt from sales and use tax. The sales of electricity and gas to florists with greenhouses and nursery operations are not subject to sales and use tax, because the greenhouse and nursery operations fall within the purview of the agricultural exemption. Florists who purchase cut flowers and prepare floral arrangements are subject to sales tax on their utility bills.

LEGAL DIVISION

September 6, 1989

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