Ruling The taxpayer's participation in a cooperative direct mailing of advertising material to Connecticut households is an advertising service. The taxpayer's services in this direct mail advertising enterprise are principally related to preparation and dissemination. Through its cooperative arrangement with a Florida company, this taxpayer arranges for the creation, preparation and distribution of material promoting a given customer's goods or services. Advertising is generally regarded as the business of preparing and circulating advertisements. The taxpayers herein are both involved in the preparation and circulation of advertising material.
Dissemination is as essential as creation in advertising.
The use of the term media is inextricably related to the concept of time and space. This concept relates to the formulation of an advertisement that is intended for mass audiences by charge for space as in newspapers and magazines or charge for time as in radio and television. The fees for Advertising services are related to charges for media placement. The concept of media placement is fundamental to the role of an advertising agency. The debate in the State Senate relating to media advertising centered around the concepts of space and time with the bill's sponsor equating time and space with media.