Rev. Rul. 54-564

A question has arisen as to the date on which the Oklahoma ad valorem taxes on real estate and personal property accrue for Federal income tax purposes.

In G. C. M. 18828, C. B. 1937-2, 87, it is held that under the law of the State of Oklahoma the ownership of real and personal property (except unmanufactured farm products) on January 1 is the "event" which fixes the liability for taxes thereon, and that real and personal property taxes accrue as of that date.

In Noble v. Jones, 45 Fed. Supp. 504, it is held that even though real and personal property located in the State of Oklahoma was required to be listed and assessed on January 1 of each year, the ad valorem taxes thereon did not become due and payable until October 1, the last day of the period during which the county board of equalization had for delivering the tax rolls to the county treasurer.

In F. A. Gillespie Trust v. Commissioner, 21 T. C. No. 81 (February 19, 1954) acquiescence page 4, this Bulletin, the court, following the decision in Noble v. Jones, supra, held that the ad valorem taxes on real estate and personal property accrue on October 1 of each year, the date on which they become due and payable.

Accordingly, it is held that the Oklahoma ad valorem taxes on real estate and personal property accrue, for Federal income tax purposes, on October 1 of each year, the date on which such taxes become due and payable by the owner of the property.

G. C. M. 18828, C. B. 1937-2, 87, modified.