Ezel / Tax Rulings / CT
CT Ruling 89-175 Sales and Use Taxes 1989-10-30

Were total receipts from an airport valet lot taxable when the price bundled parking, vehicle relocation, and shuttle transportation?

Short answer: Yes under this historical ruling. DRS treated the valet service as including a parking space and taxed total receipts, including airport shuttle transportation, without allowing allocation of part of the charge to parking. 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 airport valet-parking rule then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it. Its result depended on a bundled service providing a parking space, vehicle relocation, and airport transportation for one charge. 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

Drivers left vehicles and keys at an airport lot. Attendants moved vehicles to maximize space and returned them near the office before the drivers arrived. Vans or minibuses carried drivers, passengers, and luggage between the lot and airport terminal.

The single valet charge covered transportation and parking-space rental. DRS treated total gross receipts as taxable and would not allocate part of the charge separately to the parking space.

What this means for you

The historical ruling treated the bundled service as taxable valet parking rather than splitting parking and transportation. AN 94(3) later obsoleted the guidance.

Common questions

Were total valet receipts taxable? Yes under the ruling.

Did the charge include shuttle transportation? Yes.

Could part of the charge be allocated to the parking space? No.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(N), 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 89-175, Parking

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

Ruling 89-175

Parking

This Ruling has been obsoleted by   AN 94(3)

According to the information presented in your letter, the drivers of the motor vehicles park their vehicles in an area adjacent to the lot office. The drivers, their passengers and luggage are transported from the parking lot to the airport terminal building via mini-buses or vans by the valet parking service. When the drivers and passengers return to the airport, they are picked up by the vans or mini-buses and returned to the parking lot where they retrieve their own vehicles.

The drivers leave their keys in the motor vehicles while they are parked in the lot. The parking lot attendants relocate the motor vehicles to maximize space in the parking lot. The vehicles are returned to the area adjacent to the lot office at the time the parking lot operators are informed that the drivers are returning to the airport. The payment for the valet parking service includes transportation to and from the airport as well as rental of the parking space.

Based on the above set of facts, the total gross receipts for the airport valet parking service are subject to sales and use tax pursuant to section 12-407(2)(i)(N) of the Connecticut General Statutes, as amended by Public Act No. 89-251. The Department considers the valet parking service to include the provision of a parking space. Accordingly, the Department will not allow the allocation of a portion of the charge for a parking space.

LEGAL DIVISION

October 30, 1989

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