Renaissance Mgmt. v. Commr. of Revenue Serv.

The issue in this case is whether management fees paid to a property manager, related to reimbursement for separately stated payroll overhead expenses paid on behalf of eight separate apartment complexes, are included in the gross receipts from the sale of management services and therefore subject to the payment of a sales or use tax.

The plaintiff, Renaissance Management Company, Inc. (Renaissance), appeals from the determination by the defendant, the commissioner of revenue services (commissioner), pursuant to General Statutes § 12-422, that during the audit period of October 1, 1993,…