Ezel / Tax Rulings / CT
CT Ruling 89-258 Sales and Use Taxes 1989-12-07

Were subterranean core sampling and test-hole drilling subject to sales and use tax?

Short answer: Core sampling for engineers' predesign analysis was not taxable. Test-hole drilling was also nontaxable for new construction and existing owner-occupied one-, two-, or three-family residential property, but taxable on existing commercial, industrial, or income-producing 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 real-property service rules then in effect to core sampling and test-hole drilling. The drilling result depended on whether the work served new construction, qualifying owner-occupied residential property, or existing commercial, industrial, or income-producing property; different sites or services 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 provider performed two services. Taking core samples of subterranean strata for engineers' predesign analysis was not subject to sales and use tax.

Test-hole drilling depended on the property and project:

  • It was not taxable when performed for new construction.
  • It was not taxable on existing, exclusively residential, owner-occupied one-, two-, or three-family real property.
  • It was taxable on existing commercial, industrial, or income-producing real property.

What this means for you

The historical ruling treated core sampling differently from site-dependent test-hole drilling. For drilling, both the construction status and the existing property's use mattered.

Common questions

Was predesign core sampling taxable? No under the ruling.

Was test-hole drilling for new construction taxable? No.

What existing residential property qualified? Exclusively residential, owner-occupied property with one, two, or three families.

When was test-hole drilling taxable? When performed on existing commercial, industrial, or income-producing real property.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(I), as amended by 1989 Conn. Pub. Acts 251.

Source

Original ruling text

Ruling 89-258, Contracting

The first service that your client provides, whereby he takes core samples of subterranean strata for predesign analysis by engineers, is not subject to sales and use tax.

The second service that your client performs, which involves drilling test holes, is not taxable when rendered to new construction or existing one, two or three family exclusively residential owner-occupied real property. The test hole drilling service performed on existing commercial, industrial or income-producing real property is subject to sales and use tax pursuant to section 12-407(2)(i)(I) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

LEGAL DIVISION

December 7, 1989

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