Rev. Rul. 63-217

National banks frequently are parties to conveyances of realty. Under the provisions of section 4384 of the Internal Revenue Code of 1954, as amended, the United States or any agency or instrumentality thereof shall not be liable for the documentary stamp tax on conveyances of realty, imposed by section 4361 of the Code, with respect to an instrument to which it is a party.

Held , the exemption from liability provided by section 4384 of the Code does not apply to a national bank which is a party to a conveyance of realty, since such a bank, being a private corporation, is not an `agency or instrumentality' of the United States for purposes of that section of the Code.