Ezel / Tax Rulings / CT
CT Ruling 89-69 Sales and Use Taxes 1989-08-31

Did a company fabricating complete dump-truck covers qualify for Connecticut's manufacturing exemption on electric bills under Ruling 89-69?

Short answer: Yes. The Department concluded that machining, bending, painting, sewing, and assembling components into finished dump-truck covers for sale qualified the company for the electric-bill sales-tax exemption. The ruling is superseded.

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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 The official page says it was superseded by Policy Statement 94(3), so it is provided only as historical reference and should not be used as current authority. The ruling addressed one company's described fabrication operations 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 company qualified for an exemption from sales tax on its electric bills because it fabricated a finished product for sale: a complete dump-truck cover.

Its work included machining and drilling castings and gears, bending and painting pipe, cutting and sewing canvas, and assembling those components into the finished cover. The Department advised Northeast Utilities of the company's exempt status and said the account would receive credit for tax already collected.

The official archive says this ruling was superseded by Policy Statement 94(3).

What this means for you

The historical ruling focused on whether the company used its operations to create a finished product for sale. It does not establish current eligibility because the Department expressly marks it as superseded.

Common questions

What did the company make? Complete dump-truck covers assembled from machined castings and gears, painted pipe, and sewn canvas.

What exemption did the Department allow? An exemption from sales tax on electric bills.

What happened to tax already collected? The ruling said the utility account would be credited.

Citations and references

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

Source

Original ruling text

Ruling 89-69, Utility Exemption - Manufacturing

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

This Ruling has been superseded by PS 94(3)

Your Company fabricates dump truck covers, i.e., machines and drills casting and gears, bends and paints pipe, cuts and sews canvas and assembles it as a unit to be installed on a dump truck to keep the load covered.

Based on this description, it is the opinion of the Legal Division that your Company fabricates a finished product to be sold and, therefore, qualifies for an exemption from the sales tax on electric bills.

Northeast Utilities has been advised of your status and will make the appropriate changes to your account. Your account will also be credited for any taxes previously collected.

LEGAL DIVISION

August 31, 1989

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