Rev. Rul. 58-183

Advice has been requested whether the retailers excise tax on luggage, handbags, etc., applies to sales of certain coin holders which are designed for a particular purpose, such as holding coins to be used in parking meters or as street car or bus fares.

These coin holders are usually made of metal or a nonpliable plastic material and come in various shapes such as a bar, barrel, etc. They are designed to hold a specific number of coins of a particular denomination. Sometimes the coin holders have key chains attached.

Section 4031 of the Internal Revenue Code of 1954 imposes a retailers excise tax on the sale of luggage, handbags, etc., including purses, handbags, pocket books, wallets, billfolds, and card, pass, and key cases. Section 320.60(e) of Regulations 51, made applicable to the 1954 Code by Treasury Decision 6091, C.B. 1954-2, 47, defines the terms `purses,' `handbags,' `pocketbooks,' `wallets,' `billfolds,' and `card, pass, and key cases' to include receptacles commonly and commercially known and sold as such, regardless of design, size or materials from which made or the purpose for which they are to be used.

It is held that coin holders of the type described above, which are not suitable for use as purses, are not purses within the meaning of section 4031 of the Code and are not subject to the tax imposed thereunder. While `key cases' are embraced within section 4031 of the Code, this term is not considered to include key chains and such chains are not taxable under that statute.

See Revenue Ruling 56-274, C.B. 1956-1, as to taxability of a small plastic receptacle, which has a magnetized top for attachment to the dashboard of an automobile.