Ezel / Tax Rulings / CT
CT Ruling 89-166 Sales and Use Taxes 1989-10-27

Were a detailer's simplified roofing and siding drawings subject to Connecticut sales and use tax as architectural or engineering services?

Short answer: No under this historical ruling. The detailer extracted and condensed approved architectural and engineering information for bidding, materials, fabrication, erection, and field use, but DRS did not classify the work as taxable architectural or building-design service. DRS says AN 94(3) obsoleted it.

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 architectural and engineering-service classifications then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it. Its result depended on the detailer extracting and condensing approved drawings for subcontractor and fabrication uses. 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 information "not current" and states that Announcement (AN) 94(3) obsoleted the ruling.

Plain-English summary

The detailer extracted, simplified, and condensed information from architectural and engineering drawings for roofing and siding subcontractors and pulled material specifications for bidding.

After architect or engineer approval, the drawings could support bills of materials, manufacturer fabrication, and contractor erection and field work. DRS did not treat the detailer's services as taxable architectural, building-engineering, or building-planning and design services.

What this means for you

The historical ruling distinguished approved-detailing work from the underlying architectural and engineering design. AN 94(3) later obsoleted the guidance.

Common questions

Were the detailing services taxable? No under the ruling.

What were the drawings used for? Bidding, bills of materials, fabrication, erection, and field work.

Who approved the drawings? The architect or engineer.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as cited in the ruling.
  • Public Act No. 89-251, as cited in the ruling.
  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-166, Engineering

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

Ruling 89-166

Engineering

This Ruling has been obsoleted by   AN 94(3)

Taxpayer is a "detailer" who extracts information from architectural and engineering drawings and then simplifies and condenses them for roofing and siding subcontractors. He also pulls out specifications regarding materials for use by the subcontractors in the bid process.

After his drawings are approved by the architect or engineer, they can be used for a bill of materials, for fabrication by the manufacturer, and as erection and field drawings by the roofing and siding contractor.

It is our opinion that Taxpayer's services are not subject to the sales and use tax as architectural, building engineering, or building planning or design services under §12-407(2)(i)(F) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

LEGAL DIVISION

October 27, 1989

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