Ezel / Tax Rulings / CT
CT Ruling 89-257 Sales and Use Taxes 1989-12-07

Which furniture installation and delivery charges were taxable when furniture and movable office partitions were sold?

Short answer: The furniture sale was taxable, but a separately stated installation charge for unpacking, arranging, and connecting removable panels was not. Delivery before title passed, including moving furniture into the building, was taxable; combining delivery and installation made the full fee taxable.

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 applying the furniture-sale rules then in effect. The installation result depended on a separate charge for unpacking, arranging, and connecting movable panels that were not integral to the building, while the delivery result depended on passage of title and separate billing; different fixtures, title terms, or invoices may change the answer. The ruling does not state that it remains current. 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

The furniture sale itself was subject to sales and use tax. A separately stated installation charge was not taxable when the work consisted of removing furniture from cartons, arranging it, and connecting movable panels and partitions into office walls that could be disassembled without damaging the building and were not integral to it.

Delivery was different. Transportation before title passed was part of taxable gross receipts, and DRS viewed moving the furniture into the building as part of delivery. If delivery and installation charges were combined, the entire fee entered the tax measure for the furniture sale.

What this means for you

Under the historical ruling, separate billing and the character of the work mattered. Nontaxable installation had to be stated separately from taxable pre-title delivery.

Common questions

Was the furniture sale taxable? Yes.

Was the described installation charge taxable? No when separately stated.

Were movable office panels treated as part of the building? No under the stated facts; they could be removed without building damage and were not integral to it.

What happened if delivery and installation were combined? The combined fee was part of the taxable measure.

Citations and references

  • The published ruling cites no specific statute or regulation.

Source

Original ruling text

Ruling 89-257, Installation

The sale of furniture is subject to sales and use tax. A separately stated charge on the bill for furniture installation, which includes removing the furniture from its protective carton, arranging the furniture in a particular configuration as well as connecting movable panels and partitions to form office "walls" which are dissembled without damage to the building and not an integral part of the building, is not taxable. However, transportation charges for delivery which occurs prior to the passage of title to the furniture are part of the gross receipts of the tax. Moving the furniture into a building appears to be part of delivery. If delivery and installation charges are commingled, the fee is a part of the measure of the tax for the sale of the furniture.

LEGAL DIVISION

December 7, 1989

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