Ezel / Tax Rulings / CT
CT Ruling 89-30 Sales and Use Taxes 1989-07-17

Were vending-machine meal sales at the Veterans Home and Hospital exempt from Connecticut sales and use taxes under Ruling 89-30?

Short answer: No. The ruling found no statutory exemption for X Company Food Services' vending-machine sales. The Veterans Home and Hospital was not the purchaser of the meals, so it also could not be liable for use tax on those purchases.

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 law then in effect to vending-machine meal sales by a food-service company at the Veterans Home and Hospital. Later statutory or administrative changes may produce a different result, and another operator or institution should not assume this historical ruling controls a current transaction. 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 food and vending 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

X Company Food Services' vending-machine sales at the Veterans Home and Hospital were not exempt from sales and use taxes. The Department said there was no statutory authority for an exemption.

The Veterans Home and Hospital was not the purchaser of the meals sold through the machines, so the institution could not be liable for Connecticut use tax on those meal purchases.

What this means for you

The historical ruling looked at who actually sold and purchased the meals. Locating privately operated vending machines at an institution did not make the institution the purchaser or create an exemption for the operator's sales.

Common questions

Were the vending-machine sales exempt? No.

Was the Veterans Home and Hospital the purchaser? No.

Did the institution owe use tax on the meals? No, because it did not purchase them.

Citations and references

  • No statute or regulation was cited by section number in the ruling text.

Source

Original ruling text

Ruling 89-30, Exemptions

Ruling 89-30

Exemptions

There is no statutory authority for exempting sales made by X Company Food Services through its vending machines located at the Veterans Home and Hospital from sales and use taxes.

The Veterans Home and Hospital is not the purchaser of the meals sold through the vending machines and, accordingly, cannot be liable for Connecticut use tax on the purchases of such meals.

LEGAL DIVISION
July 17, 1989

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