Connecticut State Department of Revenue Services

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Ruling 89-210

Petroleum Gross Earnings

The petroleum company gross earnings tax is imposed on a petroleum company's gross receipts from sales of petroleum products. Unlike the sales tax, the petroleum company gross earnings tax is not a tax that is required to be passed through to customers, with the petroleum company acting as a mere collector of the tax from its customers. See Texaco Refining & Marketing Co. v. Commissioner, 202 Conn. 583 (1987).

For this reason, the fact that a Connecticut municipality is the customer to which petroleum products are sold does not affect the taxability of the petroleum company's gross receipts derived therefrom.

LEGAL DIVISION

November 14, 1989