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Ruling 90-81

Trucking and Hauling Services
Packaging and Crating Services

This Ruling has been modified by PS 94(1)

FACTS:

Company performs local and long distance trucking services which includes picking up goods from one location, transporting them to another location, and dropping off the goods. Company always furnishes a truck and driver for its transportation services.

In connection with its transportation and hauling services, Company is sometimes required to package and crate certain items of tangible personal property. These crates are often custom made by Company for its customers to securely pack the goods for shipment. Company pays Connecticut use tax on the materials used to build the crates.

RULING:

Trucking and hauling services do not fall within the categories of enumerated services subject to the sales and use tax.

Packing, crating and shipping is considered to be a personal service and not a sale of tangible personal property. Accordingly, such services are not subject to sales tax. Company is a consumer of the materials used in packaging and crating the goods and must pay use tax on the materials used to build the crates.

LEGAL DIVISION

December 20, 1990