Ezel / Tax Rulings / CT
CT Ruling 89-14 Petroleum Gross Earnings Tax 1989-06-12

When did Connecticut petroleum gross earnings tax apply to advance deposits for diesel fuel under Ruling 89-14?

Short answer: Not when the deposits were received. The tax applied only when the diesel fuel was sold because it was calculated on earnings from the first Connecticut sale of petroleum products.

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 1989 Connecticut Department of Revenue Services Ruling addressed one taxpayer's advance deposits for diesel-fuel sales under the petroleum gross earnings tax law then in effect. It does not state that it is current, and a taxpayer with different facts should not assume it controls current tax timing. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current petroleum gross earnings tax rules.
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

Advance deposits for diesel-fuel sales were not subject to Connecticut petroleum gross earnings tax when received.

The tax was calculated on earnings from the first sale of petroleum products within Connecticut. Therefore, gross earnings tax did not apply until the product was sold.

What this means for you

Under this historical ruling, receiving an advance deposit did not by itself trigger the tax. The taxable event was the petroleum-product sale.

Common questions

Were advance deposits immediately subject to the tax? No.

When did the tax apply? When the diesel fuel was sold.

What sale did the ruling identify? The first sale of the petroleum product within Connecticut.

Citations and references

  • Conn. Gen. Stat. ch. 227, as cited in the ruling.

Source

Original ruling text

Ruling 89-14, Petroleum Gross Earnings Tax

You have requested a ruling as to when advance deposits for the sale of diesel fuel are subject to gross earnings tax pursuant to Chapter 227 of the Connecticut General Statutes.

The gross earnings tax is calculated on those earnings derived from the first sale within this state of petroleum products. Accordingly, gross earnings tax is not imposed on gross earnings until there is a sale of the product. Advance deposits are not subject to gross earnings until the product is sold.

LEGAL DIVISION

June 12, 1989

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