Rev. Rul. 59-77

Section 5848 of the Internal Revenue Code of 1954 defines the term `dealer' as any person not a manufacturer or importer, engaged within the United States in the business of selling firearms. The term `dealer' includes wholesalers, pawnbrokers, and dealers in used firearms. Held , while each situation must be considered on its individual facts, the phrase `engaged within the United States in the business of selling firearms' usually denotes repeated commercial (wholesale or retail) sales of firearms with profit as the principal objective. This position is grounded on the principle that a single sale, unattended by circumstances showing the one making the sale to be engaged in the business, does not create special (occupational) tax liability.