Rev. Rul. 59-145

Advice has been requested whether the manufacturers excise tax imposed on the sale of electric light bulbs applies to the sale of a so-called `satellite bulb.'

A company imports a so-called `satellite' electric light bulb in various sizes. This `satellite bulb' consists of an electric light bulb with a covering glass crystal firmly attached so as to be considered a part of the bulb itself. The glass crystal has numerous glass `antennae,' the only purpose of which is to add to the ornamental effect of the light bulb.

Section 4131 of the Internal Revenue Code of 1954 imposes a tax upon the sale by the manufacturer, producer, or importer of electric light bulbs and tubes. Section 316.180 of Regulations 46, made applicable to the Internal Revenue Code of 1954 by Treasury Decision 6091, C.B. 1954-2, 47, defines an electric light bulb or tube as being any device designed for the diffusion of artificial light for illuminative or decorative purposes through the use of electricity.

It is held that the `satellite bulb' is an electric light bulb within the meaning of section 4131. Therefore, sales of that article are subject to the manufacturers excise tax on electric light bulbs and tubes.