Internal Revenue Service
Revenue Ruling
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smRev. Rul. 59-20
1959-1 C.B. 472
Caution: Obsoleted by Rev. Rul. 69-227
IRS Headnote
The excise tax on playing cards imposed by section 4451 of the Internal Revenue Code of 1959 does not apply to sales of a specially designed deck of cards which is used to play a game called `Hi-Fen,' and which is not suitable for use in the same manner as regular playing cards.
Full Text
Rev. Rul. 59-20
Advice has been requested whether the tax on playing cards applies to a specially designed deck of cards used to play a game called `hi-Fen.'
The game is played with a deck of 53 or possibly 54 cards consisting of 52 card faces imprinted with a letter of the alphabet, 26 cards in black and 26 cards in red, plus either one or two cards designated as `Hi-Fen.' The object of the game is to form words from the letters which appear on the cards. A `Hi-Fen' card may be used in place of any letter in forming a word. None of the cards in the `Hi-Fen' pack have pips, numerals, or pictures of figures such as the king, queen, and jack, such as appear on regular playing cards.
Section 4451 of the Internal Revenue Code of 1954 imposes a tax of 13 cents per pack on every pack of playing cards containing not more than 54 cards, manufactured or imported, and sold, or removed for consumption or sale, by a manufacturer.
Article 8 of Regulations 66, made applicable to the 1954 Code by Treasury Decision 6091, C.B. 1954-2, 47, states that the tax applies to ordinary playing cards such as are used in playing games of skill or chance such as `poker,' `euchre,' `pinochle,' and the like, and to cards that may be used in lieu of ordinary playing cards. Cards for the game of `authors,' so called, and the like, differing wholly from ordinary cards, are not subject to tax.
Accordingly, it is held that the tax on playing cards imposed by section 4451 of the Code does not apply to sales of `Hi-Fen' playing cards since they are not suitable for use in the same manner as ordinary playing cards.