Ezel / Tax Rulings / CT
CT Ruling 89-24 Sales and Use Taxes 1989-07-10

Did a hot-water heat exchanger used for handwashing qualify as machinery used directly in agricultural production under Connecticut Ruling 89-24?

Short answer: No. The ruling treated the handwashing heat exchanger as indirectly used or outside agricultural production because the activity occurred before the first production operation. It contrasted machinery used exclusively to heat water for sterilizing milk containers. The ruling is obsolete.

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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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was obsoleted by Announcement 94(5), so it is provided only as historical reference and should not be used as current authority. It addressed one hot-water heat exchanger and the direct-use agricultural machinery exemption under the law then in effect. 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 current agricultural machinery exemptions.
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

The hot-water heat exchanger did not qualify as machinery used directly in agricultural production when it heated water for handwashing.

The Department did not say the heat exchanger was not machinery. It said this use was indirect or outside the production process because handwashing occurred before the first operation in producing farm products for sale.

The ruling contrasted machinery used exclusively to heat water for sterilizing milk containers, which it gave as an example of direct production use.

The official archive says this ruling was obsoleted by Announcement 94(5).

What this means for you

The historical ruling focused on where the equipment's use fell in the production sequence, not merely whether the equipment was installed at a farm. Its obsolete status means current direct-use tests must be checked separately.

Common questions

Was the heat exchanger considered machinery? The ruling did not deny that it was machinery.

Why did the exemption fail? Its handwashing use was before the first agricultural production operation.

What use did the ruling contrast as direct? Heating water exclusively to sterilize milk containers.

Citations and references

  • Conn. Gen. Stat. § 12-412(34), as cited in the ruling.

Source

Original ruling text

Ruling 89-24, Machinery

This Ruling has been obsoleted by AN 94(5)

From the information supplied in your letter, it does not appear that the hot water heat exchanger is machinery used directly in an agricultural production process, as the phrase is used in Conn. Gen. Stat. §12-412(34). This is not to say that the heat exchanger is not machinery. This is to say that machinery used to heat water for handwashing is--unlike, e.g., machinery used exclusively to heat water to sterilize milk containers--either indirectly used in an agricultural production process or is not used in an agricultural production process at all, because it is used in an activity that is prior to the first operation in the production of farm products for sale.

LEGAL DIVISION

July 10, 1989

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