Was a custom full cranial hairpiece for a person with alopecia areata exempt from Connecticut sales and use tax?

Note -- revoked historical guidance. DRS marks this ruling "not current" and states that it was revoked by Ruling 92-12. The result below describes the 1990 ruling only; confirm current law before relying on it.

Plain-English summary

DRS ruled that the Blundell Hairpiece, a full cranial prosthesis custom-made for a person with alopecia areata, qualified for the sales-and-use-tax exemption under Conn. Gen. Stat. § 12-412(19) and Conn. Agencies Regs. § 12-426-14.

The product was made from a mold of the patient's head. A plastic skull cap was held in place by suction from that custom fit, and hair was woven into the cap. Physicians prescribed a prosthesis because alopecia areata caused body-hair loss and associated psychological problems.

The ruling was narrow. It covered the Blundell Hairpiece only when custom-made for a person with alopecia areata. The same product sold for other forms of baldness, including natural baldness, and cosmetic wigs remained taxable.

DRS later withdrew this result: the official page marks the ruling not current and says Ruling 92-12 revoked it.

What this means for you

This ruling records a historical product-specific exemption, not a current rule for wigs or cranial prostheses. Its reasoning depended on the custom construction, the patient's alopecia areata, and the prosthesis provisions then in effect. Because DRS says the ruling was revoked, sellers and buyers should confirm current treatment rather than applying the 1990 answer.

Common questions

Did the ruling exempt every wig or hairpiece? No. It exempted only the specified custom Blundell Hairpiece sold for alopecia areata. Other-baldness hairpieces and cosmetic wigs were taxable under the ruling.

Can this ruling be relied on today? No. DRS marks it not current and says Ruling 92-12 revoked it.

Citations and references

• Conn. Gen. Stat. § 12-412(19).
• Conn. Agencies Regs. § 12-426-14.
• Ruling 92-12 -- identified by DRS as revoking this ruling.

Source

• Landing page: Connecticut DRS Rulings
• Ruling: Ruling 90-53

Original ruling text

Ruling 90-53, Prostheses

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

Ruling 90-53

Prostheses

This Ruling has been revoked by   Ruling 92-12

ISSUE:

Whether the sale of a full cranial prosthesis known as the Blundell Hairpiece, which is specifically made for and sold to victims of alopecia areata, is exempt from the sales and use tax.

FACTS:

Alopecia areata is an auto-immune disease resulting in the loss of body hair. Due to the psychological problems associated with the disease, physicians prescribe a prosthesis to be worn by victims.

This full cranial prosthesis, known as the Blundell Hairpiece, is custom made from a scalp mold of the patient's head. The resulting plastic skull cap is held on the victim's head by the suction created by the custom mold. Hair is woven into the skull cap to give a natural appearance.

RULING:

It is ruled that the sale of the Blundell Hairpiece qualifies for an exemption from sales and use tax under section 12-412(19) of the Connecticut General Statutes and section 12-426-14 of the Regulations of Connecticut State Agencies. The Blundell Hairpiece is individually designed for victims of the disease known as alopecia areata.

This ruling is limited to the sale of the Blundell Hairpiece when it is custom made for victims of alopecia areata. The sale of the Blundell Hairpiece for other forms of baldness, including natural causes, as well as the sale of cosmetic wigs, is subject to the sales tax.

LEGAL DIVISION

June 19, 1990