CT Ruling 89-204 Sales and Use Taxes 1989-11-08

When were water-pump and water-purification installation or repair charges taxable under Connecticut Ruling 89-204?

Short answer: Repairs were taxable on parts and labor. Installation in new construction or qualifying owner-occupied one- to three-family residential property, including full-system replacement, was not taxable. DRS says AN 2000(8) partly obsoleted the ruling.

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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 installation and repair rules then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 2000(8) obsoleted it in part. Its results depended on repair versus installation, new construction, complete replacement, and qualifying owner-occupied residential realty. 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 -- partially obsolete historical guidance. DRS marks this information "not current" and states that Announcement (AN) 2000(8) obsoleted the ruling in part.

Plain-English summary

Repairs to water pumps in residential or commercial property were taxable on total receipts, including parts and labor. Repairing part of a water-purification system, such as its pump or other hardware, was also taxable on the full sales price.

Installing a water-purification system in new construction or in existing one-, two-, or three-family exclusively residential owner-occupied real property was not taxable. The installation charge for replacing the entire system in that qualifying existing residential realty was also not taxable.

DRS said the same framework applied to furnaces, oil burners, air conditioners, hot-water heaters, water coolers, exhaust fans, dishwashers, garbage disposals, and similar items.

What this means for you

The historical ruling distinguished installation or full replacement from repair and imposed specific residential-use conditions. AN 2000(8) later obsoleted it in part.

Common questions

Were water-pump repairs taxable? Yes, including parts and labor.

Was installation in new construction taxable? No under the ruling.

Was full replacement in qualifying owner-occupied residential realty taxable? The installation charge was not taxable.

Was repair of part of the system taxable? Yes, on parts and labor.

Citations and references

  • Announcement (AN) 2000(8) -- identified by DRS as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-204, Installation

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

Ruling 89-204

Installation

This Ruling has been obsoleted in part by   AN 2000(8)

The total gross receipts, inclusive of parts and labor, for repairing water pumps in residential or commercial property are subject to sales and use tax.

The installation of a water purification system performed in new construction or existing one, two or three family exclusively residential owner-occupied real property is not taxable.

The installation charge for replacement of an entire water purification system in an existing one, two or three family, exclusively residential, owner-occupied realty is not subject to sales tax.

The total sales price, inclusive of parts and labor, to repair part of a water purification system, such as the pump or other pieces of the hardware which is performed in residential or commercial property is subject to the tax.

The water purification system example would also apply to furnaces, oil burners, air conditioners, hot water heaters, water coolers, exhaust fans, as well as dishwashers, garbage disposals and similar items.

TIMOTHY F. BANNON

COMMISSIONER

November 8, 1989

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