Rev. Rul. 63-187

Advice has been requested whether the manufacturers excise tax imposed by section 4191 of the Internal Revenue Code of 1954 applies to the separate sale by manufacturers of the credit card recorder described below.

The article is a self-contained manually operated mechanical printing device which prints on sales invoices the information embossed in plastic or metal plates. It is rectangular in shape and is equipped with levers by means of which the operator can index the amount of a sale in the machine. In operation, a customer's credit card, showing such information as his name, address, special code numbers, etc., is inserted in the recorder along with the invoice containing information pertinent to the sale. The operator registers the total amount of the sale with the levers on the recorder and then pulls the main lever to imprint on the invoice the data from the credit card as well as the invoice data registered by the operator in the recorder itself. The credit card is returned to the customer together with a copy of the invoice.

Under the present method of operation of the various companies to which the recorder may be sold, the address information contained on a customer's credit card is not used as an addressing device. It is used only for the customer's identification if he loses his card. Moreover, the address information imprinted on the invoice from the credit card is not used in any way in connection with the processing of the invoice and the sending of it to the customer. The invoice is sent to the customer in an envelope with a completely separate card upon which the customer's address is printed by a separate machine.

Section 4191 of the Code imposes a tax upon the sale by the manufacturer, producer, or importer of certain enumerated articles, including `addressing machines.'

The credit card recorder described above is designed to transfer from a credit card to an invoice a customer's name, address, and special code numbers or other data which may be embossed on the credit card. The specific purpose for which the transferred information may be used is immaterial. Accordingly, it is held that the credit card recorder is an addressing machine within the meaning of section 4191 of the Code. Therefore, separate sales of such machine by the manufacturer thereof are subject to the tax imposed by that section.