Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 73-48

1973-1 C.B. 427

IRS Headnote

Automotive wheels designed and sold for use as replacement wheels for chassis that are interchangeable with both truck and passenger automobile vehicles are not subject to the tax on automotive parts or accessories.

Full Text

Rev. Rul. 73-48

A company manufactures and sells automotive wheels that are designed and sold for use as replacement wheels for chassis of multi-purpose vehicles of the type described in Revenue Ruling 66-308, 1966-2 C.B. 467 (examples of which are the "Bronco," "Jeep," and "Scout"). Revenue Ruling 66-308 concludes that, for purposes of the manufacturers excise tax imposed by section 4061(a) of the Internal Revenue Code of 1954, those vehicles described therein having basic open bodies without tops are passenger automobiles, while those vehicles equipped with tops are classified either as trucks or as passenger automobiles, depending solely upon the types of tops or enclosures installed on the vehicles.

Held, since the wheels referred to above are designed for use and are used as replacement wheels for chassis that are interchangeable with both the above-described trucks and passenger automobiles, such wheels come within the exception from taxation provided by section 4061(b)(2) of the Code for parts or accessories suitable for use and ordinarily used with passenger automobiles. Accordingly, sales of the wheels by the manufacturer are not subject to the tax on automotive parts or accessories imposed by section 4061(b)(1) of the Code.