Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 73-37

1973-1 C.B. 374

Sec. 1012
Sec. 1236

IRS Headnote

A dealer in securities who identifies a particular book-entry Treasury security held for investment by reference to an assigned lot number at the time of purchase satisfies the requirements of section 1.1236-1(d)(1)(ii) of the regulations; Revenue Rulings 71-15 and 71-21 amplified.

Full Text

Rev. Rul. 73-37

For the purpose of determining when a security is clearly identified in the records of a dealer in securities as a security held for investment within the meaning of section 1236 of the Internal Revenue Code of 1954, section 1.1236-1(d)(1) of the Income Tax Regulations provides that an investment security is clearly identified where there is an accounting separation of the security from other securities, as by making appropriate entries in the dealer's books of account to distinguish it from inventories and to designate it as an investment, and by (i) indicating with such entries the individual serial number of, or other characteristic symbol imprinted upon, the individual security, or (ii) adopting any other method of identification satisfactory to the Commissioner.

Held, under the amended provisions of section 1.1012-1(c)(7) of the regulations, relating to book-entry securities, wherever applicable here, T.D. 7081, 1971-1 C.B. 221, the identification of a particular book-entry Treasury security in such a dealer's books of account by reference to the unique lot number which the dealer has assigned to the lot at the time of purchase of the security is a method of identification satisfying the requirements of section 1.1236-1(d)(1)(ii) of the regulations.

Revenue Rulings 71-15 and 71-21, 1971-1 C.B., pages 149 and 221 respectively, are hereby amplified. Also compare Revenue Ruling 67-419, 1967-2 C.B. 265, as amplified by Revenue Ruling 69-416, 1969-2 C.B. 159, which provides a satisfactory method of identification under the circumstances described therein.