Ezel / Tax Rulings / CT
CT Ruling 89-225 Sales and Use Taxes 1989-11-21

Did a photocopying machine qualify for Connecticut's machinery sales-tax exemption under Conn. Gen. Stat. § 12-412(18)?

Short answer: No under this historical ruling. DRS said a photocopying machine was not exempt because copying printed pages was not considered manufacturing or fabricating an item of tangible personal property.

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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 applying the machinery exemption then in effect to a photocopying machine. The result depended on DRS's conclusion that copying printed pages was not manufacturing or fabricating tangible personal property; another taxpayer should not assume the same result for different equipment or production activity. 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

DRS concluded that a photocopying machine did not qualify for the sales-tax exemption in Conn. Gen. Stat. § 12-412(18). Copying printed pages was not considered manufacturing or fabricating an item of tangible personal property.

What this means for you

The historical exemption turned on whether the machine was used in qualifying manufacture or fabrication. Ordinary photocopying did not meet that test under the ruling.

Common questions

Was the photocopier exempt? No.

Why not? DRS did not consider copying printed pages to be manufacturing or fabrication of tangible personal property.

Citations and references

  • Conn. Gen. Stat. § 12-412(18), as cited in the ruling.

Source

Original ruling text

Ruling 89-225, Machinery/Photocopy Machines

Ruling 89-225

Machinery / Photocopy Machines

You request an opinion as to whether a photocopying machine is exempt from sales tax pursuant to Conn. Gen. Stat. § 12-412(18).

A photocopying machine is not exempt pursuant to Conn. Gen. Stat. § 12-412(18). The photocopying of printed pages is not considered to be the manufacture or fabrication of an item of tangible personal property.

LEGAL DIVISION

November 21, 1989

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