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 Rev. Rul. 56-38

1956-1 C.B. 512

Section 6011 -- Return Filing Requirement

Caution: Obsoleted by Rev. Rul. 69-227

Full Text

Rev. Rul. 56-38

In an effort to induce patrons to attend evening shows, a number of downtown motion picture theatres of a large city have arranged with parking lot operators for a special evening parking rate of 25 cents per car for their patrons. Upon payment of the parking charge, the patron is given a receipt which, when presented to the cashier at a motion picture theatre, entitles him to credit for the amount so paid on the charge for admission to the theatre. A special ticket of admission is issued to such patrons. Only one such admission is granted for each car parked, and a higher charge must be paid by or for other persons, even those who are passengers in the same car. For example, where the established price for certain accommodations is 80 cents plus admissions tax, the patron who presents a receipt for 25 cents from a parking lot operator may obtain a special ticket for 55 cents plus admissions tax, which entitles him to the use of the same accommodations as the 80 cents ticket plus tax does. No part of the parking charges is received by the theatre operators. Held , the parking charge is not an amount paid for admission, as contemplated by section 4231 of the Internal Revenue Code of 1954. Accordingly, in the example given above, the admission price of 55 cents represents a special reduced rate for patrons of the parking lot, and the tax may properly be based thereon.