CT Ruling 89-40 Sales and Use Taxes 1989-08-04

Which dry-cleaning and garment services were taxable under Connecticut Ruling 89-40?

Short answer: Mending and deterioration-prevention work was taxable repair or maintenance, while separately stated alterations were not. Monogramming and embroidery were generally taxable, but fur storage, coin-operated washers and dryers, dry-cleaning, pressing, ironing, and laundering were not.

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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 classifying specified dry-cleaning, laundry, alteration, repair, storage, monogramming, and embroidery services under the law then in effect. The ruling says its six-item list was not exhaustive, and later statutory or administrative changes may produce different results. 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 garment-service treatment.
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 ruling distinguished garment alterations from repairs and maintenance. Mending torn clothing and work that prevented deterioration were taxable repair or maintenance services. A separately stated charge for altering a new or old garment was not taxable because an alteration modified otherwise wearable clothing rather than repairing or maintaining it.

The ruling then classified six additional service groups:

  • Monogramming and embroidery were taxable, except when performed at purchase on qualifying children's clothing.
  • Fur storage was not taxable.
  • Coin-operated washers and dryers were not taxable.
  • Dry-cleaning clothes, linens, and fabrics was not taxable.
  • Pressing or ironing clothes, linens, and fabrics was not taxable.
  • Laundering soiled clothes, linens, and fabrics was not taxable.

The Department warned that this was not an exhaustive list.

What this means for you

Under the historical ruling, the nature of the garment work and separate statement of alteration charges mattered. Basic cleaning and pressing were treated differently from repair, maintenance, monogramming, and embroidery.

The source contains a separate children's-clothing exception but has an apparent typographical error in the stated age phrase, so this summary does not supply an age that the ruling text does not state clearly.

Common questions

Were alterations taxable? No, when separately stated.

Were clothing repairs taxable? Mending torn clothing and deterioration-prevention work were taxable.

Was ordinary dry-cleaning taxable? No.

Was monogramming taxable? Generally yes, subject to the ruling's children's-clothing exception.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(DD), as cited in the ruling.
  • Conn. Gen. Stat. § 12-407(2)(c), as cited in the ruling.
  • Conn. Gen. Stat. § 12-412(2)(i)(DD), as written in the ruling's alterations paragraph.
  • Special Notice Concerning the Taxation of Repair or Maintenance Services to Tangible Personal Property, LSN-96 [NEW 7/89], as cited in the ruling.

Source

Original ruling text

Ruling 89-40, Dry Cleaning

Ruling 89-40

Dry Cleaning

You have asked for clarification on what services performed by drycleaners are taxable.

Section 12-407(2)(i)(DD) of the Connecticut General Statutes which states "any repair or maintenance service to any item of tangible personal property, . . .", is the pertinent statute in regard to your services. Although the enclosed Notice does not explicitly state that alterations are outside the definition of "repair" and "maintenance", if you review the definitions of "repair" and "maintenance" contained therein, it is evident that services which mend torn clothing and which prevent the deterioration of the clothing are taxable. Since an alteration is a modification or change to an item of clothing which is otherwise suitable to wear, by implication, an alteration is not a "repair" or "maintenance" service. See Special Notice Concerning the Taxation of Repair or Maintenance Services to Tangible Personal Property (LSN-96 [NEW 7/89]).

Accordingly, separately stated charges for alterations to new or old garments are not subject to tax under the provisions of section 12-412(2)(i)(DD) of the Connecticut General Statutes.

You have also inquired if there are any other taxable services performed by drycleaners. Below I have listed six other services and have indicated whether they are subject to the imposition of a sales tax. The following is not an exhaustive list, but is provided to you so that you may inform the members of your association. The following list shall not be deemed to exclude other services from the ambit of §12-407(2)(i)(DD) of the Connecticut General Statutes.

  1. Monogramming and embroidery of clothing is a taxable activity. See section 12-407(2)(c) of the Connecticut General Statutes. If, however, an item of children's clothing (i.e., clothing for the exclusive use of children who are less than then years of age) is monogrammed and/or embroidered at the time of purchase, this service is not subject to tax.

  2. Fur storage is not subject to the tax.

  3. Washers and dryers operated by coin are not subject to the tax.

  4. Dry-cleaning of clothes, linens and fabrics are not taxable.

  5. Pressing and/or ironing of clothes, linens and fabrics are not taxable.

  6. Laundering of soiled clothes, linens and fabrics are not taxable.

LEGAL DIVISION

August 4, 1989

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