Rev. Rul. 62-221

A company manufactures various types of automobile truck bodies, all of which are subject to the manufacturers excise tax on motor vehicle articles imposed by section 4061(a) of the Internal Revenue Code of 1954. The company sells these bodies at retail only. Under the provisions of section 4216(b)(1) of the Code, it has been determined that the constructive sale price of the bodies is a specified percentage of the company's established retail price but not less than the manufacturer's cost of the bodies.

Under the company's cost accounting system, the actual cost of a particular body cannot be accurately determined at the time the body is sold; however, the company's annual cost records show very little fluctuation in the cost of manufacturing each of the various types of bodies and placing them in condition for delivery.

Held , under these circumstances, the company's actual cost of a particular type of body during the preceding year (determined in accordance with accepted accounting methods) may be used as the `cost' of a body of that type for purposes of determining the constructive sale price of such bodies sold during the current year.