This Ruling has been obsoleted by AN 94(3)
According to the information presented in your letter, the drivers of the motor vehicles park their vehicles in an area adjacent to the lot office. The drivers, their passengers and luggage are transported from the parking lot to the airport terminal building via mini-buses or vans by the valet parking service. When the drivers and passengers return to the airport, they are picked up by the vans or mini-buses and returned to the parking lot where they retrieve their own vehicles.
The drivers leave their keys in the motor vehicles while they are parked in the lot. The parking lot attendants relocate the motor vehicles to maximize space in the parking lot. The vehicles are returned to the area adjacent to the lot office at the time the parking lot operators are informed that the drivers are returning to the airport. The payment for the valet parking service includes transportation to and from the airport as well as rental of the parking space.
Based on the above set of facts, the total gross receipts for the airport valet parking service are subject to sales and use tax pursuant to section 12-407(2)(i)(N) of the Connecticut General Statutes, as amended by Public Act No. 89-251. The Department considers the valet parking service to include the provision of a parking space. Accordingly, the Department will not allow the allocation of a portion of the charge for a parking space.
October 30, 1989