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Ezel / Tax Rulings / CT
CT Ruling 90-8 Sales and Use Taxes 1990-01-31

How were the sale, installation, and removal of an underground storage tank taxed?

Short answer: The tank sale was taxable. Installation was not taxable if separately stated, but the full gross receipts were taxable when installation was bundled with the tank charge. Removing an underground storage tank was not subject to sales and use tax.

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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 addressing underground storage tank sales, installation, and removal under the law and billing facts then in effect. The published text cites no statute and does not state that the ruling remains current; later legal changes or different invoicing can change the result, so another seller or contractor should not assume it applies. 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)

Plain-English summary

DRS divided an underground storage tank transaction into three parts:

  • The tank sale was taxable.
  • Installation was not taxable when separately stated on the bill.
  • If installation was not separated from the tank charge, the entire gross receipts were taxable.

Removing an underground storage tank was not subject to sales and use tax.

What this means for you

Under the ruling, invoice presentation directly affected the installation charge. Separately stating installation preserved its nontaxable treatment; bundling it into the tank price exposed the entire charge to tax.

Common questions

Was the tank itself taxable? Yes.

Was installation taxable? Not when separately stated.

Was tank removal taxable? No under the ruling.

Citations and references

  • The published ruling cites no specific statute or regulation.

Source

Original ruling text

Ruling 90-8, Underground Tanks

Ruling 90-8

Underground Tanks

The sale of an underground storage tank is subject to sales and use tax. A separately stated installation charge on the bill is not taxable. If the installation fee is not segregated from the charge for the underground storage tax on the bill, then the total gross receipts are subject to the sales and use tax.

The removal of an underground storage tank is not subject to sales and use tax.

LEGAL DIVISION

January 31, 1990

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