Rev. Rul. 69-204

The Internal Revenue Service has reconsidered Revenue Ruling 58-487, C.B. 1958-2, 763, which holds that a self-propelled mobile home vehicle does not come within the scope of the exemption afforded house trailers by section 4063(a) of the Internal Revenue Code of 1954 and, therefore, the sales of both bodies and chassis of self-propelled mobile homes are subject to the manufacturers excise tax imposed on motor vehicle articles by section 4061(a) of the Code.

Section 801(a) of the Excise Tax Reduction Act of 1965, Public Law 89-44, C.B. 1965-2, 568, at 588, amended section 4063(a) of the Code to exempt from tax sales of bodies for self-propelled mobile homes. The exemption is effective for sales on or after June 22, 1965.

In the case of Frank Motor Homes, Inc. v. United States, 230 F. Supp. 782 (1964), affirmed, 354 F. 2d 660 (1965), the court held that the body of a self-propelled mobile home qualified for the exemption afforded house trailers by section 4063(a) of the Code (prior to its amendment), and, therefore, the sale of such body by the manufacturer was not subject to the manufacturers excise tax imposed by section 4061(a)(2) of the Code. The Service will follow this decision in the disposition of cases involving sales of such bodies prior to June 22, 1965.

Sales of chassis of self-propelled mobile homes remain subject to the tax imposed by section 4061(a) of the Code.

Revenue Ruling 58-487 is hereby superseded.