Ezel / Tax Rulings / CT
CT Ruling 89-137 Sales and Use Taxes 1989-10-10

How did Connecticut tax adjustment and testing of air-conditioning, heating, ventilation, and exhaust systems?

Short answer: Adjustment receipts were taxable for residential or commercial real estate. Testing was nontaxable in new construction and existing one-, two-, or three-family exclusively residential owner-occupied property, but taxable in existing commercial, industrial, or income-producing property.

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 is an official 1989 Connecticut Department of Revenue Services Ruling reflecting the sales-and-use-tax treatment of specified air-conditioning, heating, ventilation, and exhaust-system services then in effect. Its results distinguish adjustment from testing and depend on whether property was new construction, qualifying owner-occupied residential property, or existing commercial, industrial, or income-producing property. The source notes that Ruling 93-4 cited this ruling. 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

Total gross receipts from adjusting air-conditioning, heating, ventilation, and exhaust systems were taxable for residential or commercial real estate.

Testing those systems was nontaxable in new construction and in existing one-, two-, or three-family exclusively residential, owner-occupied property, regardless of whether an engineer, homeowner, or general contractor hired the tester.

Testing was taxable in existing commercial, industrial, or income-producing real property.

What this means for you

The historical ruling treated system adjustment as taxable and made testing depend on the property's construction and use category.

Common questions

Was system adjustment taxable? Yes for residential or commercial real estate.

Was testing in new construction taxable? No.

Was testing in a qualifying owner-occupied one-, two-, or three-family home taxable? No.

Was testing in existing commercial, industrial, or income-producing property taxable? Yes.

Citations and references

  • Ruling 93-4 -- identified by the source as citing this ruling.

Source

Original ruling text

Ruling 89-137, Engineering

This Ruling has been cited in Ruling 93-4

The total gross receipts for adjusting air conditioning, heating, ventilation and exhaust systems in residential or commercial real estate are subject to sales and use tax.

The charges for testing air conditioning, heating, ventilation and exhaust systems in new construction or existing one, two or three family exclusively residential, owner-occupied real property, are not taxable regardless of whether you are hired by an engineer, homeowner or general contractor. The charges for testing air conditioning, heating, ventilation and exhaust systems in existing commercial, industrial, or income-producing real property are subject to the sales and use tax.

LEGAL DIVISION

October 10, 1989

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