Ezel / Tax Rulings / CT
CT Ruling 89-53 Sales and Use Taxes 1989-08-15

Did a class-reunion organizer have to collect sales tax on the full ticket price under Connecticut Ruling 89-53?

Short answer: Yes. Because the organizer's arrangement fees were commingled with the event's catering, entertainment, and other costs, sales tax applied to the total ticket price. If the organizer contracted directly with caterers or entertainers, it could buy those inputs for resale with valid resale certificates. The ruling is obsolete.

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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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was obsoleted by Announcement 94(4), so it is provided only as historical reference and should not be used as current authority. It addressed one class-reunion organizer's ticket, planning, catering, entertainment, and resale-certificate arrangements under the law then in effect. 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 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 class-reunion organizer had to apply sales tax to the total ticket price because its arrangement fee was commingled with the catering, entertainment, and other event costs.

The organizer arranged the catering and entertainment, sold tickets, and paid the event bills, although the reunion committees signed the contracts with the caterers and entertainers.

If the organizer instead entered the catering or entertainment contracts directly, the ruling said it could buy those meals or entertainment without paying sales tax by giving valid resale certificates.

The official archive says this ruling was obsoleted by Announcement 94(4).

What this means for you

The historical ruling tied the taxable ticket price to the bundled presentation of the organizer's fee and event costs. It also tied resale treatment to the organizer directly entering the supplier contracts and furnishing resale certificates. Its obsolete status means current event and ticket rules must be checked separately.

Common questions

How much of the ticket price was taxable? The total sales price.

Why? The organizer's arrangement fee was commingled with the other event costs.

Could the organizer buy meals or entertainment for resale? Yes, if it contracted directly with the suppliers and furnished bona fide resale certificates.

Citations and references

  • Conn. Agencies Regs. § 12-426-1, as cited in the ruling.

Source

Original ruling text

Ruling 89-53, Consulting

This information is not current and is being provided for reference purposes only

Ruling 89-53

Consulting

This Ruling has been obsoleted by  AN 94(4)

According to the information presented in your letter, your client organizes functions for class reunions of educational institutions. Your client arranges the catering and entertainment, sells tickets and pays all the bills for each event. However, the class reunion committees enter into the contracts with the caterers and entertainers. Your client's fees for making the arrangements for the class reunions are commingled with the other costs associated with the events.

Based on the above set of facts, your client is required to apply the sales tax to the total sales price for the tickets. If your client directly enters into contracts with the caterers or entertainers, he or she may purchase the meals or entertainment without payment of sales tax by furnishing bona fide Resale Certificates pursuant to section 12-426-1 of the Regulations of Connecticut State Agencies.

LEGAL DIVISION

August 15, 1989

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