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Ezel / Tax Rulings / CT
CT Ruling 90-75 Sales and Use Taxes 1990-12-11

Were sales and rentals of graduation gowns under $75 exempt from Connecticut sales and use tax, and was an exemption certificate required?

Short answer: Yes under this historical ruling. Graduation-gown sales and rentals qualified as clothing costing under $75 under Conn. Gen. Stat. § 12-412(47), so the retailer did not need an exemption certificate. The separate public- or private-school exemptions applied only when an eligible school purchased the gowns directly. DRS marks the ruling not current and superseded by SN 92(3.1).

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 official 1990 Connecticut Department of Revenue Services guidance reflecting the clothing exemption then in effect. DRS expressly marks it 'not current' and says it was superseded by Special Notice (SN) 92(3.1). The $75 threshold and graduation-gown treatment should not be assumed current. 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Note -- superseded historical guidance. DRS marks this ruling "not current" and says it was superseded by Special Notice (SN) 92(3.1). Confirm current clothing-exemption rules.

Plain-English summary

DRS ruled that sales and rentals of graduation gowns were exempt as clothing costing under $75 under Conn. Gen. Stat. § 12-412(47). Because that clothing exemption applied directly, the retailer did not need an exemption certificate.

The ruling separately explained that the public-school or qualifying private-school exemptions in §§ 12-412(1) and (8) applied only when the school bought the gowns directly.

What this means for you

The transaction qualified through the general low-cost clothing exemption, not merely because graduation gowns were school-related. But SN 92(3.1) superseded the ruling, so the threshold and current treatment must be checked.

Common questions

Did rentals qualify too? Yes under the ruling.

Was an exemption certificate required? No, because § 12-412(47) directly exempted the transaction.

When did the school exemption matter? Only when an eligible school purchased the gowns directly.

Citations and references

  • Conn. Gen. Stat. §§ 12-412(47), 12-412(1), and 12-412(8).
  • SN 92(3.1) -- identified by DRS as superseding this ruling.

Source

Original ruling text

Ruling 90-75, Clothing Under $75

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

Ruling 90-75

Clothing Under $75

This Ruling has been superseded by   SN 92(3.1)

The sale or rental of graduation gowns are exempt from the Connecticut sales and use tax as articles of clothing costing under seventy-five dollars pursuant to Section 12-412(47) of the Connecticut General Statutes. Such sales would be exempt under Section 12-412(1), or Section 12-412(8) only if the graduation gowns were purchased directly by a public school or by a private school holding a valid sales and use tax exemption permit.

The retailer is not required to get an exemption certificate because the sales or rentals of graduation gowns are also exempt under Section 12-412(47).

LEGAL DIVISION

December 11, 1990

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