Rev. Rul. 66-210

Revenue Ruling 55-350, C.B. 1955-1, 290, deals with the computation of `gross income from the property' in the case of salt mined from underground deposits by hydraulic methods. The Revenue Ruling stated that, for purposes of computing `gross income from the property,' under section 613(c) of the Internal Revenue Code of 1954, artificial brine used as raw material in the electrolytic manufacturing of chemical products has the same value as crude rock salt at the mouth of the mine.

Where, under the facts described in the ruling or in similar fact situations, artificial brine is not sold in the raw material form but further processed, the determination of gross income from mining is to be made on the basis of the facts and circumstances of each case. Upon reconsideration of the issue, it is concluded that a direct relationship does not necessarily exist between the value of crude rock salt and the equivalent amount of salt in brine form.

Accordingly, Revenue Ruling 55-350 is hereby revoked. However, pursuant to authority contained in section 7805(b) of the Code, this revocation of Revenue Ruling 55-350 will not apply to taxable years beginning before July 5, 1966.

¹ Based on Technical Information Release 828, dated July 5, 1966.