Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 73-84

1973-1 C.B. 429

IRS Headnote

A hydraulic lift device to be mounted on a pickup truck or flat-bed trailer for purposes unrelated to the vehicle is not subject to the manufacturers tax on parts or accessories.

Full Text

Rev. Rul. 73-84

A company manufactures and sells a lift device that is designed to be mounted on pickup trucks or flat-bed trailers. The device permits various types of contractors, utility companies, farmers, etc., to work at any desired height, within certain limitations, without the use of a ladder. The article consists basically of a work platform, hydraulically-operated arms to lift the platform, and a steel-beam rack to support the complete unit.

Held, since the above-described lift device is the load being transported and its primary function is to serve a purpose unrelated to the vehicle as such, it is not an automotive part or accessory for purposes of the manufacturers excise tax imposed by section 4061(b)(1) of the Internal Revenue Code of 1954. Accordingly, sales of such devices by the manufacturer are not subject to the tax imposed by that section.