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CT Ruling 89-241 Sales and Use Taxes 1989-11-27

Which facilities counted as residential for the exemption from sales tax on gas, electricity, and heating fuel?

Short answer: Under this historical ruling, apartment buildings, nursing homes, congregate housing, and halfway houses were residential and exempt for gas, electricity, and heating fuel. Hospitals, hotels, and motels were not residential. DRS says PS 94(3) superseded the ruling.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 residential utility classification then in effect. DRS expressly says Policy Statement (PS) 94(3) superseded it. Its classification of apartment buildings, nursing homes, congregate housing, halfway houses, hospitals, hotels, and motels should not be assumed current or extended to other facilities or utility 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Note -- superseded historical guidance. DRS states that this ruling was superseded by Policy Statement (PS) 94(3).

Plain-English summary

DRS treated apartment buildings, nursing homes, congregate housing facilities, and halfway houses as residential. Their purchases of gas, electricity, and heating fuel were therefore exempt from sales tax under the historical ruling.

Hospitals, hotels, and motels were not considered residential.

What this means for you

The historical classification turned on the type of facility. PS 94(3) later superseded the ruling, so the list should be treated only as historical guidance.

Common questions

Which facilities qualified as residential? Apartment buildings, nursing homes, congregate housing facilities, and halfway houses.

Which facilities did not qualify? Hospitals, hotels, and motels.

Which utilities did the exemption cover? Gas, electricity, and heating fuel.

Citations and references

  • Policy Statement (PS) 94(3) -- identified by DRS as superseding this ruling.

Source

Original ruling text

Ruling 89-241, Utility Exemption - Residential

This Ruling is superseded by PS 94(3)

The Department considers apartment buildings, nursing homes, congregate housing facilities and halfway houses to be "residential" and therefore exempt from the sales tax imposed on the sale of gas, electricity and heating fuel.

Hospitals, hotels and motels are not considered to be residential by the Department.

LEGAL DIVISION

November 27, 1989

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