Ezel / Tax Rulings / CT
CT Ruling 89-278 Sales and Use Taxes 1989-12-14

Could a tax-exempt religious institution buy a vehicle without sales tax when it paid the full price but registered the vehicle in its rabbi's name?

Short answer: Yes under this ruling. When the institution paid the full price, bought the vehicle solely for religious purposes, and used its rabbi's name only for insurance and liability reasons, the dealer could accept a completed Registrant's Exemption Certificate and not charge sales tax.

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 sales-tax exemption to a religious institution's specific vehicle purchase. The result depended on the institution paying the full price, buying the vehicle solely for religious purposes, and registering it in the rabbi's name for insurance and liability reasons; different ownership, payment, use, or documentation 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

A tax-exempt religious institution paid the full purchase price for a motor vehicle and bought it solely for religious purposes. For insurance and liability reasons, however, the vehicle was registered in the institution's rabbi's name.

DRS ruled that the dealer could accept a completed Registrant's Exemption Certificate and avoid charging sales tax.

What this means for you

Under this ruling, registration in the rabbi's name did not defeat the exemption where the religious institution funded the entire purchase and the vehicle was solely for religious use. The ruling does not address mixed use, partial payment by another person, or different registration reasons.

Common questions

Did registration have to be in the institution's own name? No under these facts. Registration in the rabbi's name was accepted because it was done for insurance and liability reasons.

What documentation could the dealer accept? A completed Registrant's Exemption Certificate.

Could the vehicle be used for nonreligious purposes? The ruling does not say so; its result expressly rested on purchase solely for religious purposes.

Citations and references

  • The published ruling cites no specific statute or regulation.

Source

Original ruling text

Ruling 89-278, Exemption - Charitable

Ruling 89-278

Exemption - Charitable

You have inquired as to whether a motor vehicle can be purchased without paying sales tax therefore when the full purchase price is paid by a tax exempt religious institution but, for reasons of insurance and liability, such vehicle is registered in the name of the Rabbi.

It is the position of this Department that where payment is provided by the religious institution, the vehicle is being purchased solely for religious purposes, and the registration of such vehicle is in the name of this institution's Rabbi, the vendor of such motor vehicle may accept a completed "Registrant's Exemption Certificate" (copy enclosed) and thereby be relieved of charging a sales tax.

LEGAL DIVISION

December 14, 1989

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