Rev. Rul. 64-88

A company manufacturers and sells an `embossing punch' and an `embossing control' which are designed for use in combination as an attachment to an embossing machine. The purpose of the attachment, which will not function independently, is to emboss on plastic credit cards coded dots in addition to the other information that is entered on the cards by the embossing machine. The control portion of the attachment contains a punched paper tape `reading' mechanism from which information is obtained to control the punch portion.

Held , the embossing punch and control are not themselves taxable articles within the meaning of section 4191 of the Internal Revenue Code of 1954. Rather, they are accessories for a taxable embossing machine. Consequently, the manufacturers excise tax imposed by that section does not apply to separate sales of the embossing punch and control. However, where they are sold on or in connection with a taxable embossing machine by the manufacturer of the embossing machine, the tax applies to the sale of the complete machine (including these accessories).