Internal Revenue Service
Revenue Ruling

TaxLinks.com   sm

 Rev. Rul. 72-63

1972-1 C.B. 333

IRS Headnote

A tank body, including the heating, pumping, and piping mechanism installed thereon, mounted on a highway truck chassis and used for transporting bituminous roofing material to a jobsite is subject to the manufacturers tax on motor vehicles.

Full Text

Rev. Rul. 72-63

A company manufactures and sells a tank body that ranges in size from 1,000 to 3,500 gallons capacity and is designed to be mounted on a highway truck chassis. The tank body is insulated and equipped with a heating mechanism, a pump, and certain piping. It is used to transport bituminous roofing material over the highway to a jobsite where it is used to heat and maintain the temperature of the material and pump the material to the rooftop.

Held, sales by the manufacturer of the tank body described above are subject to the tax imposed by section 4061(a)(1) of the Internal Revenue Code of 1954 since it is designed for the transportation of property on the highway. The described items of equipment installed on the tank body are "parts or accessories therefor" within the meaning of section 4061(a)(1) of the Code and charges for such items are includible in the sale price of the body upon which the tax is based.

See Revenue Ruling 69-206, C.B. 1969-1, 278, which holds that a tank body, including the heating and pumping mechanism installed thereon, mounted on a truck or trailer chassis and used to spray bituminous materials over road surfaces is subject to the manufacturers excise tax on motor vehicles.