🧪 TEST MODE ACTIVE Use test card: 4242 4242 4242 4242
Ezel / Tax Rulings / CT
CT Ruling 90-56 Sales and Use Taxes 1990-07-10

Were independent dietetic counseling and kitchen-operation services provided to nursing homes taxable consulting services in Connecticut?

Short answer: Yes under this historical ruling. The dietitian reviewed patient histories and eating habits, advised staff on special diets and food preparation, educated patients and families, and reviewed kitchen sanitation and efficiency. Because food and nutrition were key parts of the nursing home's total patient care, DRS classified the work as taxable business analysis, management, and consulting under § 12-407(2)(i)(J) and the cited regulation. DRS marks the ruling not current and obsoleted by AN 94(4).

Apply this to your situation

This page answers the general question as of 1990. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1990
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 1990 Connecticut Department of Revenue Services Ruling reflecting the taxable consulting-service rules then in effect. DRS expressly marks it 'not current' and says it was obsoleted by Announcement (AN) 94(4). Current treatment of dietetic, health-care, and nursing-home consulting must be confirmed. 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 marks this ruling "not current" and states that it was obsoleted by Announcement (AN) 94(4).

Plain-English summary

An independent dietitian reviewed patients' medical histories and eating habits, advised nursing staff and food-service supervisors on special diets, educated patients and families, and reviewed kitchen sanitation, efficiency, and food preparation.

DRS held the services were taxable business analysis, management, and consulting. Nursing homes provided total patient care, including food and nutrition, and dietetic counseling was a key element of that business.

What this means for you

The historical ruling looked at the service's role in the customer's business, not merely its health-care content. AN 94(4) later obsoleted the classification.

Common questions

Did direct patient education avoid tax? No. It was part of the overall taxable engagement described by DRS.

Why was kitchen review included? Sanitation, efficiency, and special-diet preparation supported the nursing home's care operations.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(J).
  • Conn. Agencies Regs. § 12-426-27(b)(10).
  • Announcement (AN) 94(4).

Source

Original ruling text

Ruling 90-56, Consulting Services / Dieticians

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

Ruling 90-56

Consulting Services /  Dietitians

This Ruling has been obsoleted by   AN 94(4)

ISSUE:

Whether dietetic counseling services provided by an independent contractor to nursing homes, nursing home employees and to patients in a nursing home are subject to sales and use tax under Section 12-407(2)(i)(J) as business analysis, management, consulting and public relations services.

FACTS:

The dietetic consulting services consist of a review of each patient's medical history with the nursing home staff to determine dietary requirements, discussions with the nursing staff regarding patients' eating habits and providing the staff with information on special diets, apprising the food services supervisor as to the patient's dietary requirements and the foods to be, or not to be, served to particular patients, and a review of kitchen operations and recommendations on sanitation, efficiency of operations and the proper preparation of special diets.

The consulting services further involve diet education and instruction with patients, determination of patients' food preferences and its suitability for them, preparation of special diets, and discussions with family members on the patient's dietary requirements.

RULING:

Nursing homes are in the business of providing total care to their patients including food and nutrition services. Dietetic counseling is a key element in providing total care.

Thus, the rendering of dietetic counseling services to nursing homes are taxable business analysis, management and consulting services pursuant to Section 12-407(2)(i)(J) and Regulations Section 12-426-27(b)(10).

LEGAL DIVISION

July 10, 1990

Get today's answer for your situation

You just read a 1990 ruling on this question. Ezel checks current Connecticut tax law and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.